TRANSPORT

Openings in A class divisions... fire doors in main vertical zone bulkheads shall be of the self closing type with easy means of release from the open position. PSCO observed all class A fire doors of the engineering space were not able to self close and held open with hold back devices.

Radio installations...shall be protected against harmful effects of water, extremes of temperature and other adverse environmental conditions. PCSO observed inadequate closure of the GDMSS batteries.

Where A class divions are pierced for the passage of pipes arrangements shall be made to ensure that the fire resistance is not impaired. PCSO observed an opening in the bulkhead below the HAVC hatch being used as a drain.

The company and the ship shall comply with the requirements of the International Safety Management Code. For the purpose of this regulation, the requirements of the Code shall be treated as mandatory. The company should establish procedures to ensure that the ship is maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the company. In meeting these requirements, the company should ensure that any non-conformity is reported, with its possible cause, if known. PSCO’s observed that the vessel has not been maintained in conformity with the provisions of the relevant rules and regulations, including: invalid SOLAS certificates, the crew training manual was not in the working language of the crew, the oil record book and garbage record book were missing the master’s signatures, and bunker delivery receipts were missing the Sulphur content level. An external audit is recommended. 74 SOLAS (20) IX/3.1 ISM Code Part A/10.1

If a ship at the time when a certificate expires is not in a port in which it is to be surveyed, the Administration may extend the period of validity of the certificate but this extension shall be granted only for the purpose of allowing the ship to complete its voyage to the port in which it is to be surveyed, and then only in cases where it appears proper and reasonable to do so. Vessel could not produce valid, full-term Cargo Ship Safety Construction Certificate. At the time of the exam, the vessel possessed two Interim Cargo Ship Safety Construction Certificates issued consecutively. 74 SOLAS (20) Ch.1 Reg. 14 (e)

A cargo ship shall be subject to a minimum of two inspections of the outside of the ship’s bottom during any five-year period, except where regulation 14(e) or (f) is applicable. Where regulation 14(e) or (f) is applicable, this five-year period may be extended to coincide with the extended period of validity of the certificate. In all cases the interval between any two such inspections shall not exceed 36 months. The vessel has only had one inspection of the outside of the ship’s bottom in the last five years when it went to drydock in December of 2021 (the last inspection before that was in January 2018). 74 SOLAS (20) Ch. I/10(a)(v)

The training manual shall be written in the working language of the ship. The vessel’s established working language is English. However, the Crew Training Manual was only written in Spanish. Not all crew members comprehend Spanish. 74 SOLAS (20) III/35.5

For each ship subject to regulation 5 and 6 of this Annex, details of fuel oil for combustion purposes delivered to and used onboard shall be recorded by means of a bunker delivery note that shall contain at least the information specified in appendix V to this Annex. Sulphur content of the fuel oil was not recorded on the bunker delivery note. MARPOL Annex VI Regulation 18.5

… Each completed operation shall be signed by the officer or officers in charge of operations concerned and each completed page or group of electronic entries shall be signed be the master of the ship. Oil Record Book had multiple pages without the master of the ship’s signature. MARPOL ANNEX 1 Regulation 17.4

Each completed page or group of electronic entries of the Garbage Record Book shall be signed by the master of the ship. Garbage Record Book had multiple pages without the master of the ship’s signature. MARPOL Annex V Regulation 10.3.1

The company and the ship shall comply with the requirements of the International Safety Managment Code. For the purpose of this regulation, the requirements of the Code shall be treated as mandatory. The company should establish procedures to ensure that the shipis maintained in conformity with the provisions of the relevant rules and regulations and with any additional requirements which may be established by the company. In meeting these requirements, the company should ensure that any non-conformity is reported, with its possible cause, if known. PSCO’s observed that the vessel failed to properly report 5 leaks in the fire main piping, 1 leaking valve along the fire main, 3 inoperable smoke detectors in the engine room, a fuel oil leak from the main diesel engine fuel day tank, a broken sprinkler head in the paint locker, and a fuel leak from the main service generators fuel oil storage tank. An ISM audit is required prior to departure. 74 SOLAS (2020)IX/3.1 ISM Code Part A/10.1

All required fire detection systems shall be capable of automatically indicating the presence or indication of fire and also its location. PSCOs identified 03 inoperable smoke detectors were found inside machinery space. SOLAS 60 III / 61

Control exercised by a duly authorized control officer under article X shall be limited to the following…assessment, in accordance with section A-1/4…Specifically section A-1/4.4 of the code. The chief engineer did not know how to operate the OWS during the inspection. STCW A-I/4

...Pipes conveying oil or combustible liquids shall be of a material approved by the administration having regard to the fire risk.... PSCO’s observed the pipe to the auxiliary engine storage tank leaked combustible liquids and presented a fire risk. 60 SOLAS CH II/49(b)

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. PSCO’s observed numerous issues with fire main system including but not limited to 5 holes in piping, missing sprinkler ampules inside paint locker, leaking fire hydrant valve on aft deck and excessive corrosion throughout the entire fire main piping. 74 SOLAS (20) I/11(a)

Fire-fighting systems and appliances shall be kept in good order and readily available for immediate use. CO2 system was missing 2 bottles and the distribution piping was disconnected. Evidence shows that Master has notified company on missing hydrostatic release inspection. Company failed to provide the vessel with requested inspections. 74 SOLAS (2020)II-2/14.2.1.2

Maintenance, testing, and inspections shall be carried out based on the guidelines developed by the Organization and in a manner having due regard to ensuring the reliability of firefighting systems and appliances. PSCO’s observed that the vessel’s crew was not conducting the required inspections for firefighting appliances and also did not have any records onboard. 74 Solas (20) XI-2/4.2

The renewal survey shall include an inspection of the structure, machinery and equipment as referred to in paragraph (b)(i) to ensure that they comply with the requirements of the present regulations, are in satisfactory condition and are fit for the service for which the ship is intended. PSCOs observed the main diesel engine day tank manholes and valves were leaking fuel, and nothing was noted on the certificate nor reported. 74 SOLAS (20) I/10 (b)(ii)

While all reasonable steps shall be taken to maintain the equipment in efficient working order to ensure compliance with all the functional requirements specified in regulation 4... PSCOs observed inadequate maintenance of GMDSS equipment as crew did not maintain adequate records of daily, weekly, and monthly tests of equipment. The last monthly test of SART and EPIRB was conducted on March 23, 2023 74 SOLAS (20) IV/15.8

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present regulations to ensure the ship in all respects will remain fit to proceed to sea without danger to the ship or persons on board. PSCO’s observed MDE day tank leaks. 74 SOLAS (20) I/11(a)

Where davits are recovered by action, of the falls by power, safety devices shall be fitted which will automatically cut off the power before the davit comes against the stops in order to avoid overstressing the wire rope falls or davits. PSCOs observed inoperable rescue boat davit limit switch. SOLAS 60 III / 36 (K)

Fire-Fighting systems and appliances shall be kept in good working order and readily available for immediate use. PSCO’s observed fire extinguishers tied with rope and not ready for immediate use. 74 SOLAS (20)/II-2 14.2.1.2

Cylinder must always be secured and, when not in use, they must be stowed in a rack in an upright position, with the valve protection cap in place. PSCOs observed Acetylene bottles stored on deck improperly secured; bottles were not stowed in a braced rack. 46 CFR 147.60(b)(1)

No person may cause a vessel to enter into or get underway on the navigable waters of the United States unless no more than 12 hours before entering or getting underway, the following equipment has been tested: (...) The vessel was missing entries for pre-arrival checks IAW CFR 33 CFR 164.25

The VGP applies to discharges incidental to the normal operation of all non-recreational vessels of 79 feet or greater in length. In addition, the ballast water discharge provisions also apply to any non-recreational vessel of less than 79 feet or commercial fishing vessel of any size discharging ballast water.Discharges (or treatment works treating domestic sewage) seeking coverage under a general permit shall submit to the Director a notice of intent to be covered by the general permit. The vessel did not submit a Notice of Intent (NOI) for their VGP. 46 CFR 122.28(b)(2)

All windows and side scuttles in bulkheads within accommodation spaces shall be constructed so as to preserve the integrity requirements of the type of bulkhead in which they are fitted. Dogging mechanism for aft deck window is corroded and not able to be closed causing a weathertight integrity issue. 60 SOLAS I/46 (b)

EACH ABANDON SHIP DRILL SHALL INCLUDE: REPORTING TO STATIONS AND PREPARING FOR THE DUTIES DESCRIBED IN THE MUSTER LIST PSCOS OBSERVED OUTDATED MUSTER LIST CREATING CONFUSION WITH ASSIGNED DUTIES AMONGST CREWMEMBERS. SOLAS(2020) 111/19

A RECORD SHALL BE KEPT, TO THE SATISFACTION OF THE ADMINISTRATION AND AS REQUIRED BY THE RADIO REGULATIONS, OF ALL INCIDENTS CONNECTED WITH THE RADIOCOMMUNICATION SERVICE WHICH APPEAR TO BE OF IMPORTANCE TO SAFETY OF LIFE AT SEA. PSCOS OBSERVED LAPSES IN RECORD KEEPING REQUIREMENTS DURING INPORT PORT CALLS. SOLAS(2020) IV/17 50ac

ALL THE LIFE—SAVING APPLIANCES SHALL BE KEPT IN WORKING ORDER AND AVAILABLE FOR INMEDIATE USE BEFORE TEH SHIP LEAVES PORT AND AT ALL TIMES DURING THE VOYAGE PSCOS OBSERVED LIFE BUOY ON PORT BRIDGE WING HAD MULTIPLE LARGE TEARS. SOLAS (60) III/4.c 1OC

All the life saving appliances shall be kept in working order and available for immediate use before the ship leaves port and at all times during the voyage. PSCOs observed rescue boat not capable of immediate use based on annual inspection results.

Davits, falls, blocks, and all other gear shall be of such strength that the lifeboats can be turned out manned by a launching crew and then safely lowered with the full complemnt of persons and equipment... PSCO observed rescue boat winch wire broken, davit wire rope guide missing, thus davit is not capable of strength to safely lower persons and equipment.

The means for securing and maintaining weathertightness shall be to the satisfaction of the administration. The arrangements shall ensure that the tightness can be maintained in ant sea conditions. PSCO observed both daylight and rain coming through weathertight hatch of emergency escape of steering gear room.

The company and the ship shall comply with the requirements of the ISM code. the company should establish procedures to ensure that all personnel new and transferred are given proper familiarization with their duties. PSCO identified that only the captain and chief mate have acknowledged that they have read and signed the attestation page in front of the SMS per instructions under 6.2 in the SMS. 74SOLAS (2020 CONS) IX/3.1 ISM Code 6.3

In any cargo ship there shall be permanently exhibited for the guidance of the ship officers general arrangements plans showing clearly for each... fire resisting bulkhead...fire extinguishing appliance...PSSCO's observed multiple conflicting details listing on the fire control plan for the tween decks, and the key for the plan to include but not limited to: fire extinguishers type noted on the plan did not match the space, missing doors, bulkheads indicated were there isn't owe, safety appliances not in locations indicated, ETC. 60SOLAS II/ reg 70

All Doors... in A class divisions shall provide resistance to fire as wall as the passage of smoke and flame. PSCO observed rag stuffed in top of door where gasket was missing in door from ECR to generator 2 and 3 space in engine room. 60 SOLAS II/reg.38(d)

15106 - The company should establish procedures, plans and instructions including checklist as appropriate for key shipboard operations concerning the safety of the personnel ship and protection of the environment. PSCO observed inconsistencies between the SMS procedures for the life-saving and firefighting maintenance and the planned maintenance manual, resulting in discrepancies onboard maintenance and record-keeping. Recommend external audit for SMS procedures. -74 SOLAS (20)IX/3.1 & ISM Code Part A/7 -50 a,b,c

15106 - The company should establish procedures by which the ships personnel receive relevant information on the safety management system in a working language or languages understood by them. PSCO observed the entire crew spoke Spanish except for the chief engineer who only spoke English. The ships official language is English. The vessels emergency instructions are in English but all training manuals are in Spanish. Drills where conducted in Spanish. -74 SOLAS (20)IX/3.1 & ISM Code Part A/6.6 -50 a,b,c

01315 - Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the oil record book part one. PSC Officer observed the Chief engineer has not been recording weekly soundings in the oil record book. -MARPOL (17 cons.) Annex I/17.4 -50 a,c

CG006 - Ballast water into the waters of the United States, the master, owner, operator, agent or person in charge of a vessel subject to 151.2025 of this subpart must either ensure that the ballast water meets the ballast water discharge standard in 151.2030(a), use an AMS as described in 151.2025(a)(3), or ballast with water from a U.S. public water system, according to the schedule in paragraph (b) of this section. Subject vessel, of keel laid date 20JUL1970 and ballast water capacity of 498 m3 , is past its compliance date per the implementation schedule in 33 CFR 151.2035 (b). Vessel’s current ballast water management method is exchange and discharge, which is not authorized. Vessel has no BWTS installed. Vessel is not authorized to discharge untreated ballast into U.S. waters. -33 CFR 151.2035 -15c

Oil filtering equipment required to...in paragraph 1 of this regulation shall be designed approved by the adminstration...considering the design of such equipment...shall have regard to the specification recommended by the organization. Vessel's crew informed PSCO's that they did not have a copy of the manufacturer's instructions on how to maintain & operate their MEPC 60(33) OWS per the organizations recommendations.

Oil filtering equipment referred to in paragraph 1 of this regulation shall be of a design approved by the administration... PSCO's observed installation of 02 additional testing valve in OWS system that is not approved by flag. MARPOL(17cons)Annex I/14.6

After any survey of the ship under regulations 7,8,9 or 10 has been completed, no change shall been made in structural arrangements, machinery, equipments, covered by the survey, without the sanction of the administration... The fuel shutoff cable was broken that was connected to the quick closing valve of the auxiliary generator fuel tank. 60SOLASI/11

The construction of all doors and door frames in "A" class divisions. With the means of securing them when closed, shall provide resistance to fire as well as to the passage of smoke and flame as far as practicable equivalent to that of the bulkheads in which the doors are situated... The CO2 control room door has severe wastage at the bottom knife edge including worn and warped gasket material allowing for clear passage of air and light when the door is closed. 60SOLASII-2/38.(d)

Crew members with enclosed space entry or rescue responsibilities shall participate in an space entry and rescue drill to be held on board the ship at least once every two months... The crew has not conducted drills for enclosed space entry within the past 5 months. 74SOLAS(19cons)III/19.3.3

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the oil record book part 1... Chief engineer has not been recording weekly soundings in the oil record book since October 16th, 2020. MARPOL(17cons)Annex I/17.4

Every ship of 100 gross tonnage and above... Shall carry a garbage management plan which the crew shall follow... Such a plan shall be based on the guidelines developed by the organization. Ship garbage management plan is not current with MEPC resolutions. MARPOL(17cons)Annex V/10.2

OBJECTIVE EVIDENCE DISCOVERED DURING AN EXPANDED ISM EXAM REVEALED THE FOLLOWING NON-CONFORMITIES: THE VESSEL FAILED TO FULLY IMPLEMENT THE REQUIREMENTS OF THE ISM CODE THROUGH THEIR SMS PROCEDURES AS EVIDENT BY THE FOLLOWING DEFICIENCIES INDICATING THAT THE SHIP AND/OR COMPANY ARE NOT MEETING THE SMS REQUIREMENTS. RECOMMEND AN EXTERNAL AUDIT. SEE FORM B 74SOLAS (14CONS) IX/3.1 ISM CODE PART A REG 6.1.2, 7, 8.2, 10.2.4, 11.2.3

THE CERTIFICATES ISSUED UNDER REGULATIONS 12 AND 13 SHALL BE READILY AVAILABLE ON BOARD FOR EXAMINATION AT ALL TIMES. VESSEL UNABLE TO PROVIDE AN ORIGINAL SOLAS CARGO EQUIPMENT CERTIFICATE INCLUDING FORM E.74 SOLAS (14 Cons.) CHAPTER I, REG 16

A RECORD SHALL BE KEPT, TO THE SATISFACTION OF THE ADMINISTRATION AND AS REQUIRED BY THE RADIO REGULATIONS, OF ALL INCIDENTS CONNECTED WITH THE RADIOCOMMUNICATION SERVICE WHICH APPEAR TO BE OF IMPORTANCE TO SAFETY OF LIFE AT SEA. VESSEL’S GMDSS LOG ONLY HAVE THREE ENTRIES, EACH ON DECEMBER 20, JANUARY 10, AND FEBRUARY 13. 74 SOLAS (14 Cons.) CHAPTER IV, REG 17

EVERY SEAFARER HOLDING A CERTIFICATE...SHALL ALSO HOLD A VALID MEDICAL CERTIFICATE ISSUED IN ACCORDANCE WITH...SECTION A-1/9 OF THE STCW CODE. PSCO’S FOUND ONE ABLE SEAMAN MEDICAL CERTIFICATE MISSING VISUAL ACUITY, COLOR VISION AND HEARING INFORMATION. VESSEL AND A/B WAS UNABLE TO PROVIDE DATE OR DOCUMENTATION FROM LAST COLOR TEST CONDUCTED. 78 STCW (17 Cons.) CHAPTER I, REG I/9.3

SYSTEMS AND EQUIPMENT USED TO MEET THE REQUIREMENTS OF THIS REGULATION SHALL CONFORM TO PERFORMANCE STANDARDS AND FUNCTIONAL REQUIREMENTS…EQUIPMENT SHALL BE OF A TYPE APPROVED BY THE ADMINISTRATION. VESSEL DOES NOT HAVE A LRIT CONFORMANCE TEST ONBOARD. 74 SOLAS (14 Cons.) CHAPTER V, Ref 19-1.6

THE CONDITION OF THE SHIP AND ITS EQUIPMENT SHALL BE MAINTIAINED TO CONFORM WITH THE PROVISIONS OF THE PRESENT REGULATIONS TO ENSURE THAT THE SHIP IN ALL RESPECTS WILL REMAIN FIT TO PROCEED TO SEA WITHOUT DANGER TO THE SHIP OR PERSONS ONBOARD. PSCOs OBSERVED 1 ¾ FULL 5-GALLON BUCKET OF LUBE OIL LOCATED UNDER THE VENT PIPE OF THE MAIN ENGINE SUMP TANK WHICH WAS USED AS A CATCH FOR TANK OVERFLOW, OILY RAGS, AND STEEL BULKHEAD PARTIALLY COVERED IN LUBE OIL. 74 SOLAS (14 Cons.) Ch 1, Reg. 11.1

FIRE EXTINGUISHERS SHALL BE KEPT IN GOOD ORDER AND AVAILABLE FOR IMMEDIATE USE. 04 FIRE EXTINGUISHERS WERE FOUND IMPROPERLY SECURED WITH ROPE OR WITHOUT PROVIDED BRACKETS IN THE ENGINE SPACE.

MECHANICAL AND EQUIPMENT PRESENTING HAZARDS TO PERSONNEL SHALL HAVE INSTALLATIONS OF BUILT-IN GUARDS FOR MOVING PARTS. 02 STEERING PUMP SHAFTS WERE UNGUARDED PRESENTING A HAZARD TO CREW. ILO 147 Art. 4 PWSA 33 USC 1233(b)

The boundary bulkheads and decks separating accommodation spaces from... service spaces shall be constructed as "A" class divisions. Bulkheads separating the galley from both the dining rooms have openings which have wood hinged doors, not meeting "A" class. Additionally port side dining room opening only has 1 of 2 hinged door. SOLAS (1960) Chap. 2 Reg. 40

The following nautical and hydrographic services: Nautical charts, sailing directions, lists of lights, tide tables, and other nautical publications. Vessel does not have the most up to date. 74 SOLAS (14) V/9.2.2

The load line mark shall consist of a ring 300 mm inside diameter and 25 mm wide which is interested by a horizontal line 450 mm in length and 25 mm in breath. Vessel's stbd side load line mark has an additional line within the ring. ICLL (1966) reg 5

The garbage record book shall be kept on board the ship... this document shall be preserved for a period of at least two years from the date of the last entry. Ship only has records going back to Dec 3rd 2019 Onboard. MARPOL V/10.3.3

A lifebuoy shall satisfy the following requirements: it shall be of a highly visible colour and shall be marked in block letters with the name and port of register. Block letters are faded on quick release buoys. SOLAS 1960 III/21(a)(v)

The company should establish procedures to ensure the ship is maintained in conformity with relevant rules and regs. In meeting these requirements the company should ensure that: inspections are held at appropriate intervals. LSA Safety checks IAW SMS are not being carried out. Immersion suit lights are missing. Buoys need to be addressed. ISM Code 10.1 ISM Code 10.2.2

In... any cargo ship, there shall be permanently exhibited for the guidance of the ship's officers general arrangement plans showing clearly for each deck the control stations, the various fire sections enclosed by fire-resisting bulk heads, the sections enclosed by fire-retarding bulkheads. The vessel's fire control plan does not show the galley enclosed by a class A Boundary. Coast Guard recommends a complete review of the fire control plan to be in compliance with SOLAS 60 requirements. 60 SOLAS II/70

SHIPBOARD INCINERATION SHALL BE ALLOWED ONLY THROUGH THE USE OF AN APPROVED SHIPBOARD INCINERATOR. DURING THE PSC EXAM, THE PSCO DISCOVERED A METAL DRUM SUSPECTED TO BE USED BY THE CREW TO INCINERATE GARBAGE. UPON FURTHER INQUIRY, THE MASTER STATED THAT THE CREW USES THE DRUM FOR INCINERATATION. THE GARBAGE RECORD BOOK SHOWS MULTIPLE ENTRIES FOR THE INCINERASTION OF GARBAGE FROM 5/21/14 TO 11/24/19. THE IAPP ALSO STATES THAT THE SHIP IS NOT OUTFITTED WITH A SHIPBOARD INCINERATOR. FURTHERMORE, THE SHIP'S FLAG ADMINISTRATION HAS ISSUED AN ATTESTATION LETTER STATING THE VESSEL IS NOT OUTFITTED WITH AN APROVED SHIPBOARD INCINERATOR

Every company should develop procedures to prepare for and respond to emergency situations.. Vessel is using a training EEBD which is of a different make and model from EEBDs used for actual emergencies. 74 SOLAS(14 CONS) IX.3.1 ISM CODE 1.4.5

THE HULL, MACHINERY AND EQUIPMENT...SHALL BE SURVEYED.. AT SUCH INTERVALS AS THE ADMINISTRATION MAY CONSIDER NECESSATY IN ORDER TO ENSURE THAT THEIR CONDITION IS IN ALL RESPECTS SATISFACTORY. PSCOS OBSERVED FUEL LEAKS FROM M/ENG DAY TANK SIGHT GLASS AND QUICK CLOSING VALVES, AUX ENG DAY TANK AND PORT GENERATOR INJECTOR LEAK DETECTION LINES. 60 SOLAS I/10

ALL REQUIRED FIRE DETECTION SYSTEMS SHALL BE CAPABLE OF AUTOMATICALLY INDICATING THE PRESENCE OR INDICATION OF FIRE AND ALSO ITS LOCATION. SMOKE DETECTOR ABOVE SHIP GENERATORS WAS INOPERABLE. SMOKE DETECTOR IN SHIPS WORKSHOP WAS NOT GIVING AN ALARM IN THE SPACE. 60 SOLAS II/61(a)

... PLANS AND BOOKLETS SHALL BE KEPT UP TO DATE, ANY ALTERATIONS BEING RECORDED THERE ON AS SOON AS PRACTICABLE. FIRE CONTROL PLANS DO NOT SHARE MARKING FOR " A CLASS" BOUNDARIES. ADDITIONALLY, FCP REQUIRES THAT 03 FIRE FIGHTING OUTFITS BE KEPT ON BOARD. CURRENTLY THERE ARE 02 ONBOARD AND ONLY 01 OF WHICH IS SERVICEABLE. 60 SOLAS II/70

WITHIN THE ACCOMODATION SPACES.. ALL DOORWAYS AND SIMILAR OPENINGS SHALL HAVE A METHOD OF CLOSURE CONSISTENT WITH THE TYPE OF BULKHEAD IN WHICH THEY ARE SITUATED. DOORS TO INDIVIDUAL CREW ACCOMODATIONS HAVE BEEN ALTERED IN A WAY THAT CREATES AN OPENING IN THE BOUNDARY WHEN THE DOORS ARE CLOSED. 60 SOLAS II/39 (a)(1)

ALL CARGOES, SHALL BE LOADED, STORED AND SECURED IN ACCORDANCE WITH THE CARGO SECURING MANUAL. THE VESSELS CARGO SECURING MANUAL DOES NOT CONTAIN PROVISIONS TO LOAD, STOW OR SECURE VEHICLES, PALLETS AND OTHER NON CONTAINERIZED CARGOES CURRETNLY ON BOARD THE VESSEL. 74 SOLAS (14 CONS) VI / 5.6

THE PERSONIN CHARGE OF A VESSEL EQUIPPED WITH BALLAST TANKS MUST EMPLOY ONE OF THE METHIDS LISTED IN 33 CFR 151.2025 PSCOS OBSERVED B.W. DISCHARGES ENTRIES IN THE B.W. RECORD BOOK THAT OCURRED WHILE THE VESSEL WAS MOORED IN THE MIAMI RIVER. VESSEL DOES NOT MEET ANY OTHER B.W. MAHAGEMENT REQUIREMENTS. 33CFR 151.2025 (a)

[withheld — contains personal information; the deficiency system, dates, and resolution status are shown above]

THE COMPANY SHOULD ENSURE THAT ALL PERSONNEL INVOLVED IN THE COMPANY SAFETY MANAGEMENT SYSTEM HAVE AN ADEQUATE UNDERSTANDING OF RELEVANT RULES AND REGULATIONS, CODES AND GUIDELINES. CAPTAIN COULD NOT PROVIDE ANY RECORDS OF FAMILIARIZATION TRAINING FOR MEMBERS THAT REPORT ONBOARD. 74 SOLAS IX/3.1 ISM CODE 6.4

SUCH CERTIFICATE SHALL BE ISSUED OR ENDORSED BY THE ADMINISTRATION OR BY ANY PERSONS OF ORGANIZATIONS DULY AUTHORIZED BY IT. IN EVERY CASE THE ADMINISTRATION ASSUMES FULL RESPONSIBILITY FOR THE CERTIFICATE. THE IOPP CERTIFICATE STATES THAT THE VESSEL HAS A MEPC 107 OWS. HOWEVER THE VESSEL HAS A MEPC 60 ONBOARD. MARPOL 2017 ANNEX 1/7.2

SUCH CERTIFICATE SHALL BE ISSUED OR ENDORSED BY THE ADMINISTRATION OR BY ANY PERSONS OF ORGANIZATIONS DULY AUTHORIZED BY IT. IN EVERY CASE THE ADMINISTRATION ASSUMES FULL RESPONSIBILITY FOR THE CERTIFICATE. THE IAPP STATES THAT THERE IS NO INCINERATOR ONBOARD. THE [name withheld] USE A BARREL TO INCINERATE. MARPOL 2017 ANNEX VI/6.3

THE LINES WHICH INDICATE THE LOAD LINE ASSIGNED IN ACCORDANCE WITH THESE REGULATIONS...SHALL EXTEND FORWARD OF THE CENTER OF THE RING. THE LOAD LINES ON THE VESSEL ARE INCORRECTLY MARKED AND DO NOT MATCH THE LOAD LINE CERTIFICATE. ICLL 66/88 REG. 6

11134 - Operation of Life Saving Appliances - Where mechanically powered appliances are fitted for the recovery of the rescue boat, safety devices shall be fitted which will automatically cut off the power before the davits come against the stops in order to avoid overstressing the wire rope falls or davits. Limit switch was operating in the reverse direction. During operational test limit switch activation wire broke. - 60 SOLAS III/36(K)

11134 - Operation of Life Saving Appliances - Where mechanically powered appliances are fitted for the recovery of the rescue boat, safety devices shall be fitted which will automatically cut off the power before the davits come against the stops in order to avoid overstressing the wire rope falls or davits. Limit switch on rescue boat davit is inoperable. - 60 SOLAS III/36(K)

The Port and Starboard side sliding doors on the bridge were found to not be weather tight, additionally the bridge overhead was leaking near the bookshelves.

At the request of the administration to cause a ship to be surveyed. the satisfied survey that the provisions of Annex I are complied with shall issue or authorize the issue of an Internation Oil Pollution Prevention Certificate. the IOPP states that the vessel has a 107(49) oil content meter and a 107(49) OWS. The vessel has in fact a 60(33) oil content meter and a 60(33) OWS.

SOLAS 60, Reg 26 (a)(iii)(2): A vessel less than 5000GT shall have a self contained emergency source of power with starting arrangements to the satisfaction of the administration. The emergency generator is designed to have two battery banks, one battery bank is not operational.

A vehicle is not subject to the requirements of 49 CFR 176.905 if they meet an exception outlined in 49 CFR 176.905(i). The vessel stated they comply with 49 CFR 176.905(i)(3). However the batteries for the loaded vehicles in the cargo hold were not disconnected.

A lifejacket shall be provided for every person on board the ship with a lifejacket light IAW the lifesaving appliances code III 12.2.3. Lifejacket did not have required functioning light.

All openings in the exposed weather deck shall be provided with efficent means for expeditously closing them watertight. Coaming on the emergency generator room door is degraded and needs replacement.

The condition of the ship and its equipment shall be maintained to conform with the provisions of the regulations to ensure that the ship in all respects will remain fit to proceed to sear without danger to the ship or persons onboard. No lagging on maine engine #5 cylinder.

At least 3 two way VHF radio telephone aparatus shall be provided on every cargo ship of 500 GT and upwards. One battery for emergency radio is expired. 74 Solas (14 cons) CH III Part B Reg 6.2.1.1

The fire main and water service pipes shall be sufficient for the effective distribution of the maximum required discharge. Pin hole in fire main port side immediately adjacent to super structure rendering pressure inadequate. 60 Solas CH II Part E Reg 56 (c)

The condition of the ship and its equipment shall be maintained to conformw with the provisions of the present regulations to ensure that the ship in all respects will remain fit to proceed to sea without danger to the ship or persons onboard. The vessel only has one of two anchors. Install anchor to satisfaction of the administration. 74SOLAS Con. 14, Ch 1, Reg 11