OCEAN SPIRIT I

Objective evidence discovered during an expanded ISM exam revealed the following non-conformities: the crew failed to fully implement the requirements of the ISM Code through their SMS procedures. These identified deficiencies are evidence that the ship and/or company are not meeting the SMS requirements. Recommend an external audit. See Form B 74 SOLAS (2014) IX/3.1, ISM Code 1.3, ISM Code 1.4.2, ISM Code 5.1.1, ISM Code 5.1.2, ISM Code 6.4, ISM Code 7, ISM Code 10.1

Repairs, alterations and modifications which substantially alter the dimensions of a ship shall meet the requirements for ships constructed on or after July 2002* (corrected per footnote under II-2/regulation 1) in so far as the Administration deems reasonable and practicable. The ship underwent a modification of a major character while registered with the United States in 2006; however, it was not brought into compliance with 74 SOLAS / II-2 after it was sold foreign and entered international service. 74 SOLAS(2014) II-2/1.3.2

Such certificates, if valid, shall be accepted unless there are clear grounds for believing that the condition of the ship does not correspond substantially with the particulars of the certificates or that the ship is not in compliances with the provisions of regulation 11(a) and (b). The design of the vessel is not built in accordance with the fire class divisions or integrity standards of 74 SOLAS, and yet the Recognized Organization issued SOLAS certificates attesting to full compliance with II-2. 74 SOLAS (2014) I/19(b)

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

A certificate issued under regulation 7 of this Annex shall cease to be valid in any of the following cases: if the relevant surveys are not completed within the periods specified under regulation 6.1 of this Annex. The anniversary date of the International Oil Pollution Prevention Certificate is 3 May 2018. The completion date of the survey on which the certificate is based is 12 January 2017. In accordance with regulation 6.1, an annual survey should have been completed within three months before or after the anniversary date in May 2017. The certificate is not endorsed to indicate a survey was completed. The master stated Flag/RO surveyors had not performed a survey since the initial survey and had only been onboard during the June 2017 detention. The certificates were reissued on 9 June 2017 without an annual survey endorsement. MARPOL 73/78 Annex I/10.9.1

Accommodation and service spaces and control stations of cargo ships shall be protected by a fixed fire detention and fire alarm system as follows, depending on a protection method adapted in accordance with regulation 9.2.3.1. The fire detection and alarm system throughout the accommodation spaces (crew cabins), low and high risk service spaces (laundry, storeroom, and galley), and control station (navigation bridge) are localized household modular smoke detectors, which are not fixed and do not meet any of the schemes from 9.2.3.1. 74 SOLAS (2014) II-2/7.5.5

A fixed fire detection and fire alarm system required in this regulation and other regulations in this part shall be of an approved type and comply with the Fire Safety Systems Code. The vessel does not have a fixed fire detection and alarm system complying with the FSS Code; instead, it has localized household modular smoke detectors fitted in the accommodation spaces, low and high risk service spaces, and the control station, which do not have two sources of power, hardwiring, a centralized system, a two-minute escalating alarm, etc. The category A machinery space has a fixed heat detection system with a corresponding panel that alarms at the control station, and the galley has one fixed heat detector. The crew states the galley heat detector also alerts on the bridge, in direct contravention of FSS Code, Ch. 9, 2.4.1.2. This could not be conclusively verified as the alarm panel was repetitiously sounding even after multiple attempts to acknowledge and silence it.

Stairways which penetrate more than a single deck shall be surrounded by at least “A-0” class divisions and be protected by self-closing doors at all levels. The stairway penetrates two decks, and its boundaries are not insulated. The door between corridor/lobby serving the accommodation spaces on deck 2 and the control station on deck 3 is solid-wood construction with no fire rating and is not self-closing, and there is no door in the stairway between the corridor serving the accommodation spaces on deck 2 and the high risk service space (galley) on deck 1. 74 SOLAS (2014) II-2/9.2.3.4.1

The fire resistance of doors shall be equivalent to that of the division in which they are fitted, this being determined in accordance with the Fire Test Procedures Code. Doors throughout the ship, except those weathertight doors immediately leading to the open deck, are solid wood construction without fire ratings. 74 SOLAS (2014) II-2/9.4.2.1

In cargo ships, non-combustible bulkheads, ceilings, and linings filled in accommodation and service spaces may be faced with combustible materials provided such spaces are in accordance with the provisions of paragraphs 3.2.2 to 3.2.4 and regulation 6. The accommodation spaces, low and high risk service spaces, and the control station are paneled with mobile home construction grade wood laminate and other flammable materials. The crew was unable to provide a certificate attesting to compliance with 3.2.2 to 3.2.4 and regulation 6. 74 SOLAS (2014) II-2/5.3.2.1.2

In addition to complying with the specific provisions for fire integrity of bulkheads and decks of cargo ships, the minimum fire integrity of bulkheads and decks shall be as prescribed in tables 9.5 and 9.6. The fire integrity of the bulkheads and decks is not in compliance with the structural fire protection tables 9.5 and 9.6. For instance, there is no structural fire protection insulation throughout the category A machinery space and the accommodation spaces (crew cabins) immediately below the control station (navigation bridge) are not insulated to “A-60” class standard on the ceiling forming the control station deck in accordance with table 9.6. 74 SOLAS (2014) II-2/9.2.3.3.1

Power ventilation of accommodation spaces, service spaces, cargo spaces, control stations, and machinery spaces shall be capable of being stopped from an easily accessible position outside the space being served. This position shall not be readily cut off in the event of a fire in the spaces served. Two positions for emergency ventilation shut down are marked on the fire control plan. The controls for one of these, on the bridge, is not labeled, and the master could not identify it. 74 SOLAS (2014) II-2/5.2.1.2

Means of control shall be provided for closure of openings in funnels which normally allow exhaust ventilation and closure of ventilator dampers. There are no means to close the exhaust ventilation funnels. 74 SOLAS (2014) II-2/5.2.2.1

Ducts provided for the ventilation of machinery spaces of category A and galleys shall not pass through accommodation spaces, service spaces, or control stations unless they comply with the conditions specified in paragraphs 7.2.1.1.1 to 7.2.1.1.4 or 7.2.1.2.1 and 7.2.1.2.2 below. The ventilation system is divided in two: one serves the accommodation spaces; low and high risk service spaces; and the control station and the other serves the category A machinery space. None of the ventilation ducts have automatic fire dampers and none are insulated to "A-60" class standard. 74 SOLAS (2014) II-2/9.7.2

An automatic fire damper shall be fitted in the galley ventilation duct near the ventilation unit. There is no automatic fire damper in the galley ventilation duct. 74 SOLAS (2014) II-2/9.7.2.1

Where ventilation ducts with a free cross-sectional area exceeding 0.02 meters squared pass through “A” class bulkheads or decks, the opening shall be lined with a steel sheet sleeve. These ducts, or sleeves lining such ducts, shall be provided with fire insulation. The insulation shall have at least the same fire integrity as the bulkhead or deck through which the duct passes; and ducts with a free cross-sectional area exceeding 0.075 meters squared shall be fitted with fire dampers in addition to the requirements of paragraph 7.3.1.1. The fire damper shall operate automatically, but shall also be capable of being closed manually from both sides of the bulkhead or deck. The damper shall be provided with an indicator which shows whether the damper is open or closed. Fire dampers shall be easily accessible. Where they are placed behind ceilings or linings, these ceiling or linings shall be provided with an inspection door on which a plate reporting the identification number of the fire damper is provided. The fire damper identification number shall also be placed on any remote controls required. There are multiple ventilation ducts in the engine room which are not insulated and do not have fire dampers. 74 SOLAS (2014) II-2/7.3

Structural members and all blocks, falls, padeyes, links, fastenings and all other fittings used in connection with launching equipment shall be designed with a factor of safety on the basis of the maximum working load assigned and the ultimate strengths of the materials used for construction. The plaque permanently affixed to the rescue boat states the max loaded weight including persons, engine, and equipment is 1,495lbs. Accounting for the minimum safety factors, the davit arm and winch should be rated for 6727.5lbs and 8970lbs, respectively. The rescue boat davit arm and winch do not state a service weight limit, and no documentation onboard supports that it was satisfactorily certified before being placed into service for its intended use. The davit was previously identified as deficient for a separate issue during the June 2017 detention. 74 SOLAS (2014) III/17.3 LSA 6.1.1.6

The condition of the ship and its equipment shall be maintained to conform with the provisions of the present convention to ensure that the ship in all respects will remain fit to proceed to sea without presenting an unreasonable threat of harm to the marine environment. During the initial test of the OWS, a thick, black oily mixture was observed discharging through the sample outlet past the solenoid valve. The visibly contaminated effluent continued to discharge and the sensor did not appear to register the contamination. After allowing the engineer to clean the sensor probe in accordance with the manufacturer's instructions and subsequent system tests, the system appeared to be working in-sync and the effluent discharged was no longer highly contaminated. The crew was unable to provide proof of system calibration. Subsequently, a manufacturer's technician was called and confirmed the system installed without an OCD only cleans the oily water and does not actually ensure the effluent is less than 15ppm. There was no OCD installed. MARPOL 73/78 Annex I/6.4.1

Piping to and from oil residue (sludge) tanks shall have no direct connection overboard, other than the standard discharge connection referred to in regulation 13. The overboard discharge for the OWS runs vertically for approximately 3m and horizontally for approximately 10m to the exact opposite side of the engine room where it directly connects to the bilge system's overboard spool piece. The piping is not painted or sealed and at multiple junctions could easily be disconnected to fit a bypass to the OWS as no means have been implemented to prevent tampering. The piping just before the connection to the spool piece contains a gate and check valve, approximately 13m after the OWS solenoid valve. Neither of the valves are locked or otherwise sealed. This section of piping, as well as the valves, were contaminated with black oily waste. In addition, there is piping running from the bilge pockets under the water-lubricated port and starboard shaft seals and the aft lazerette passageway with cam-lock fittings that directly connect to the same section of the bilge system's spool piece. The shaft seal draining piping is by-passing the OWS. There is evidence that fresh water from the leaking propeller shaft seals is being pumped and subsequently cleaning the pipe of any oil residue passing through the gate and check valves. MARPOL 73/78 Annex I/12.3

General arrangement plans shall be permanently exhibited for the guidance of the ship's officers showing clearly for each deck the control stations, the various fire sections enclosed by "A" class divisions, the sections enclosed by "B" class divisions together with particulars of the fire detection and fire alarm systems, the sprinkler installation, the fire-extinguishing appliances, means of access to different compartments, decks, etc., and the ventilating system, including particulars of the fan control positions, the position of dampers and identification numbers of the ventilating fans serving each section. The fire control plan does not list "B" class divisions or the particulars of the ventilation, specifically: the fire dampers and the identification numbers of the ventilating fans serving each section. 74 SOLAS (2014) II-2/15.2.4

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the Oil Record Book Part I, so that all entries in the book appropriate to that operation are completed. The engineer has not been logging all ORB entries as required between 1 October 2017 and 1 May 2018. Entries for non-automatic discharges only state the quantity in barrels, the time of operation start and stop, and the latitude/longitude location while always omitting the method of discharge or disposal (e.g. through oil filtering equipment, to reception facilities, or internally transferred). Consequently, there are numerous unaccounted for entries where it is difficult or impossible to determine through record review which method was employed. Issues with the previous engineer properly and accurately completing ORB entries were identified during the June 2017 detention. MARPOL 73/78 Annex I/17.4

Any discharge into the sea of oil or oily mixtures from ships of 400 gross tonnage and above shall be prohibited except when all the following conditions are satisfied: the oily mixture is processed through an oil filtering equipment and the oil content of the effluent without dilution does not exceed 15 ppm. There are three bilge pockets from which make-shift piping has been connected to drain them: under the starboard propeller shaft packing gland, under the port propeller shaft packing gland, and in the aft lazerette passageway. This piping connects to the bilge piping overboard discharge spool piece. During the June 2017 detention, automatic submersible bilge pumps were discovered in each of these three bilge wells and were subsequently removed as corrective action. An automatic submersible bilge pump with a direct overboard connection was found installed in the bilge well under the starboard propeller shaft packing again on 1 May 2018. This condition directly by-passes the oily water separator and allows for discharging of oily waste in excess of 15 ppm by simply pouring it into these bilge wells.

Control exercised by a duly authorized control officer under article X shall be limited to the following: assessment, in accordance with section A-I/4 of the STCW Code, of the ability of the seafarers of the ship to maintain watchkeeping and security standards, as appropriate, as required by the Convention if there are clear grounds for believing that such standards are not being maintained because any of the following have occurred: the ship is otherwise being operated in such a manner as to pose a danger to the environment. The arrangement of the OWS system and associated piping has allowed for the strong possibility of illegal discharges of oily waste. The engineering complement onboard did not identify the arrangement as deficient.

Deficiencies which may be deemed to pose a danger to the environment include the following: absence in a watch of a person qualified to operate equipment essential to the prevention of marine pollution. The engineer was not familiar with the OWS's manufacturer instructions manual, which includes a sample diagram of how the system should be installed and visually appear. Consequently, he operated the system without realizing it was missing an oil content detector.

The condition of the ship and its equipment shall be maintained 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 on board. Both forward and aft service generators, particularly the aft one, have severe oil leaks which are pooling on hot surfaces and steaming. An identical deficient condition was observed during the June 2017 detention. 74 SOLAS (2014) I/11(a)

A HAZMAT employee must receive the training required by this subpart at least once every three years. The chief mate could not provide proof of hazmat training within the past 3 years. 49 CFR 172.704(c)(2)

A training manual shall be provided. There was no training manual onboard meeting the requirements of II-2/15.2.3. 74 SOLAS (2014) II-2/15.2.3.1

The purpose of this regulation is to provide information and instructions for proper ship and cargo handling operations in relation to fire safety. For this purpose, the following functional requirements shall be met: fire safety operational booklets shall be provided on board. There are no fire safety operational booklets on board.

Drills shall, as far as practicable, be conducted as if there were an actual emergency. During the first drill, the captain began the drill before the lead PSCO could question him regarding the ship's procedures and what should be expected to be seen. Mid-drill, the lead PSCO asked the captain how many crewmembers should be donning fireman outfits, and he stated "Two," however, only one crewmember donned a fireman outfit. The crew was provided feedback with emphasis on clear crew procedures and communication, and the first drill was discounted. They were permitted a second opportunity to perform the fire drill. During the second drill, the on-scene PSCO witnessed one of the crewmembers not donning the fireman outfit properly: the SCBA bottle was upside down and the facemask was loose. The crew also pre-staged with equipment ready and hoses faked out. Feedback was provided again regarding properly donning the fireman outfit, and the crew were permitted a third and final opportunity to perform the fire drill in a different location without pre-staged equipment. The third fire drill was satisfactory. 74 SOLAS (2014) III/19.3.3.1

Every ship to which Chapter 1 applies shall carry an appropriate portable atmosphere-testing instrument. As a minimum, these shall be capable of measuring concentrations of oxygen, flammable gases of vapors, hydrogen sulfide and carbon monoxide prior to entry into enclosed spaces. Suitable means shall be provided for the calibration of all such instruments. The vessel does not have portable atmosphere testing equipment or a means to calibrate one if so provided. 74 SOLAS (2014) XI-1/7

A training manual complying with the requirements of paragraph 3 shall be provided. There was no training manual onboard meeting the requirements of paragraph 3. 74 SOLAS (2014) III/35.2

Where the contents and use of a space are such that there is a doubt as to its classification for the purpose of this regulation, or where it is possible to assign two or more classifications to a space, it shall be treated as a space within the relevant category having the most stringent boundary requirements. The space containing the fixed emergency fire pump is between a store room (category 5) and the open ro-ro cargo deck (category 11) which carries dangerous goods in greater than limited or excepted quantities. The seawater inlet for the fixed emergency fire pump is a plastic green flexible hose penetrating the bulkhead of the space, running on the cargo deck, and overboard into the water. In addition to potentially affecting the ready availability of fire-fighting capability by the very nature of its design and deployability (II-2/14.2.1.2), the plastic hose compromises the class division of whatever the space category is considered. 74 SOLAS (2014) II-2/9.2.3.3.2

Materials readily rendered ineffective by heat shall not be used for fire mains and hydrants unless adequately protected. There is a span of pipe between the fixed emergency fire pump and the fire main is plastic/PVC material that is readily rendered ineffective by heat. 74 SOLAS (2014) II-2/10.2.1.1

Arrangements shall be made to ensure immediate availability of a supply of water from the fire main at the required pressure either by permanent pressurization or by suitably placed remote arrangements for the fire pumps. The fire main is not permanently pressurized, and the fixed emergency fire pump is not provided with remote starting arrangements and is not self-priming. 74 SOLAS (2014) II-2/19.3.1.1

The quantity of water delivered shall be capable of supplying four nozzles of a size and at pressures as specified in regulation 10.2, capable of being trained on any part of the cargo space when empty. The fixed emergency fire pump is not capable of supplying four nozzles at the pressures specified in regulation 10.2. 74 SOLAS (2014) II-2/19.3.1.2

The capacity of the pump shall not be less than 40% of the total capacity of the fire pumps required by regulation II-2/10.2.2.4.1 of the Convention and in any case not less than the following: for cargo ships of less than 2,000 gross tonnage: 15 m3/h. The fixed emergency fire pump is not is not capable of supplying the fire main at the pressure specified. 74 SOLAS (2014) II-2/10.2.2.3.1.2, FFS Code Ch. 12.2.2.1.1.2

When the pump is delivering the quantity of water required by paragraph 2.2.1.1, the pressure at any hydrants shall be not less than the minimum pressure required by chapter II-2 of the Convention. The pressure at the hydrant should be 0.25 N/mm2 (36psi). The pressure at the pump while supplying only one nozzle is approximately .193 N/mm2 (28psi). 74 SOLAS (2014) II-2/10.2.2.3.1.2 FFS Code Ch. 12.2.2.1.2

Any service fuel tank shall contain sufficient fuel to enable the pump to run on full load for at least 3 h and sufficient reserves of fuel shall be available outside the machinery space of category A to enable the pump to be run on full load for an additional 15 h. The fixed emergency fire pump does not have a dedicated fuel tank capable of running for 3 h and did not have designated reserves of fuel to enable it to be run on full load for an additional 15 h. 74 SOLAS (2014) II-2/10.2.2.3.1.2 FSS Code Ch. 12.2.2.2.2

A ship shall be subjected to the surveys and inspections specified below: a periodic inspection within 3 months either way of each annual anniversary date of the certificate. The anniversary date of the International Load Line Certificate is 3 May 2018. The completion date of the survey on which the certificates is based is 12 January 2017. The certificate should have had an annual survey within three months before or after the anniversary date in May 2017. The certificate is not endorsed to indicate a survey was completed. The master stated Flag/RO surveyors had not performed a survey since the initial survey and had only been onboard during the June 2017 detention. The certificates were reissued on 9 June 2017 without an annual survey endorsement. ICLL 66 Article 14(1)(c)

A certificate issued under regulation 6 of this Annex shall cease to be valid in any of the following cases: if the relevant surveys are not completed within the periods specified under regulation 5.1 of this Annex. In accordance with regulation 5.1, an annual survey should have been completed within three months before or after the anniversary date in May 2017. The certificate is not endorsed to indicate a survey was completed. The master stated Flag/RO surveyors had not performed a survey since the initial survey and had only been onboard during the June 2017 detention. The certificates were reissued on 9 June 2017 without an annual survey endorsement. MARPOL 73/78 Annex VI/9.9.1

All ships of 150 gross tons and upward shall be fitted with a spare magnetic compass, interchangeable with the magnetic compass on the conning station or other means to preform that function by means of replacement or duplicate equipment. The vessel did not have a spare magnetic compass. The safety equipment certificate has an asterisk next to the spare magnetic compass, among several other equipment items, and states as a footnote: "*Alternative means of meeting this requirement are permitted under regulation V/19. In case of other means, they shall be specified." However, no alternative means are specified on the certificate or elsewhere. 74 SOLAS (2014) V/19.2.2.1

The ANOA submitted for the OCEAN SPIRIT I was missing information required by 33 CFR 160.206.

There are no records or logs of daily rest hours on board the vessel. 95STCW2010 VIII/1.9

Cargo carried on deck shall be so loaded and secured as to prevent damage to ship and persons aboard. Cargo stowed on main deck completely blocking egress of crew from house emergency exit. 74 SOLAS 2014 VI/5.1 – 17bc

Whenever an accident occurs to a ship or a defect is discovered, either of which affects the safety of the ship, the master or owner of the ship shall report at the earliest opportunity to the administration, the nominated surveyor or RO responsible for issuing the relevant certificate, who shall cause investigations to be initiated to determine whether a survey, as required by regulation 7, 8, 9, or 10, is necessary. Vessel aground on ST Thomas, USVI with unknown damage to hull and propulsion gear. 74 SOLAS 2014 I/11(c) – 17abc

The oil record book shall be completed on each occasion whenever any of the following take place on the ship. (.3) Collection or disposal of bilge water. (.4) discharge of bilge water which has accumulated. Oil record book does not have weekly soundings of tanks listed in 3.1 of the IOPP. Bilge water overboard discharge (D13) does not have quantity of discharge recorded. MARPOL 73/78 Annex I/17.2

Objective evidence discovered during an expanded ISM exam revealed the following non-conformities. These discrepancies, included with the other material deficiencies, are evidence that the ship and/or crew are not meeting the requirements of the ISM Code. Recommend an external audit. See Form B for full details.

Ships must be provided with an emergency fire pump permanently connected to the fire main complying with the provisions of the FSS Code. The vessel's fire pump is portable and does not have a designated location meeting the SFP requirements of a control station. The RO identified issue in February and did not compel compliance. 74 SOLAS (2014), Ch. II-2 / Reg. 10.2.2.3.1.2, FSS Code 12.2.1

Bulkheads forming boundaries between cargo spaces and machinery spaces of category A shall be insulated to "A-60" class standard. Other boundaries between such spaces shall be insulated to "A-60" class standard. The engine room overhead is not insulted to "A-60" class standard. 74 SOLAS (2014), Ch. II-2 / Reg. 19.3.8

Cargo ships shall carry at least one rescue boat complying with the requirements of section 5.1 of the Code. A rescue boat shall be capable of carrying at least five seated persons and a person lying on a stretcher. The vessel's rescue boat is not SOLAS approved and it is only rated for three people. 74 SOLAS (2014), Ch. III / Reg. 31.2, LSA 5.1.1.3

Each rescue boat launching appliance shall be fitted w/ a powered winch motor capable of raising it from the water w/ its full complement of persons & equipment at a rate of not less than 0.3m/s. The powered winch cannot meet this requirement, & the vessel & launching appliance were surveyed w/ the current three-person rescue boat. 74 SOLAS (2014), Ch. III / Reg. 17.3, LSA Code 6.1.1.9

Control exercised by a duly authorized control officer under article X shall be limited to the following: verification that the numbers and certificates of the seafarers serving on board are in conformity with the applicable safe manning requirements of the Administration. The senior engineer holds a III/1 operational license that does not meet the III/3 requirements listed on the MSMD.

Deficiencies which may be deemed to pose a danger to the environment include the following: failure to comply with the applicable safe manning requirements of the Administration and absence in a watch of a person qualified to operate equipment essential to prevention of marine pollution. The senior engineer required one-on-one instruction and hours of practice to prove operation of the OWS.

The condition of the ship and its equipment shall be maintained 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 the persons on board. Both propeller shaft packing glands are leaking sea water at approximately ten gallons per minute in a steady stream. 74 SOLAS (2014), Ch. I / Reg.11(a)

The arrangements for the storage, distribution & utilization of oil used in pressure lubrication system shall be such as to ensure the safety of the ship and persons on board. An excessive amount of fresh oil was discovered on & below the operating aft generator & approximately 300-500 gallons of densely contaminated oily waste was observed within the bilge wells creating a severe fire hazard.

Plans & booklets shall be kept up to date. The fire control plan was last verified in June 2016 & listed inaccurate locations of spaces onboard including the CO2 locker & an auxiliary machinery space the crew was using as a paint locker. These spaces reflect the arrangement of the vessel prior to the 2006 major modification. In addition, the plan is missing the location of both fireman outfits.

Any discharge into the sea of oil or oily mixtures from ships of 400 gross tonnage & above shall be prohibited except when all the following conditions are satisfied: the oily mixture is processed through an oil filtering equipment &; the oil content of the effluent without dilution does not exceed 15 ppm. Energized auto. bilge pumps w/ direct overboard connections overboard were placed in bilge.

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the Oil Record Book Part I, so that all entries in the book appropriate to that operation are completed. The ORB has not been properly maintained since 10 March 2017. MARPOL 73/78, Annex I, Reg. 17.4

The bunker delivery note shall be accompanied by a representative sample of the fuel oil delivered. The sample is to be retained under the ship’s control in any case for a period of not less than 12 months from the time of delivery. All fuel samples have not been maintained for 12 months: the oldest sample onboard is from December 2016.

The Oil Record Book Part I shall be kept on board the ship and preserved for a period of three years after the last entry has been made. The oldest entry in the current ORB is 26 October 2016. The vessel has been operating on international voyages in U.S. waters since 19 July 2016 according to Coast Guard records. The current log states the most recent voyage is number 574.

A duplicate set of fire control plans or a booklet containing such plans shall be permanently stored in a prominently marked weather tight enclosure outside the deckhouse for the assistance of shore-side fire-fighting personnel. There was no permanent storage location for the fire control plan, and no plan located outside the deckhouse. 74 SOLAS (2014), Ch. II-2 / Reg. 15.2.4.2

Fixed fire detection shall be periodically tested by means of equipment producing hot air at the appropriate temperature, or smoke or aerosol particles having the appropriate range of density or particle size to which the detector is designed to respond. There are no manufacturer's instructions or testing procedures on board to determine the appropriate method to test the installed heat detectors.

Fire protection systems and fire-fighting systems and appliances shall be maintained ready for use. One thermal detector in the engine room above the aft generator was not operational. 74 SOLAS (2014), Ch II-2, Reg 14.1.1

Not less than two of these shall also be provided with lifebuoy self-activating smoke signals and be capable of quick release from the navigation bridge. The life buoys on the navigation bridge are stowed in brackets and there is no pull-bar for quick-release. If the stowage arrangement was designed for quick release, the ring buoys would fall to the deck below in their current arrangement.

At least 3 two-way VHF radiotelephone apparatus shall be provided on every cargo ship of 500 gross tonnage and upwards. The vessel only has two of the three required survival craft radios on board meeting the requirements of Resolution A.809(19) including a battery with tamper-proof seal. 74 SOLAS (2014), Ch III, Reg 6.2.1.1

Posters or signs shall be provided on or in the vicinity of survival craft and their launching controls and shall: illustrate the purpose of controls and the procedures for operating the appliance and give relevant instructions or warnings. The instructions provided for the vessel’s rescue boat is for a self-righting fast rescue boat. 74 SOLAS (2014), Ch III / Reg 9.2.1

Satisfactory means, permanently attached, shall be provided for closing the openings of the air pipes. The goose neck pipe to the mud tank on the port side is missing its closing device. ICLL 66, Annex I / Reg 20

Drills shall, as far as practicable, be conducted as if there were an actual emergency. The first fire drill conducted was failed due to improper communication between the bridge and those on scene and for the fire fighting outfit not properly donned. Drills were repeated and the errors were corrected. 74 SOLAS (2014), Ch III / Reg 19.3.1

DAMAGED FUELS INJECTORS ARE CAUSING THE VESSEL TO HAVE AN UNUSUALLY LARGE AMOUNT OF SMOKE TO BE RELEASED FROM THE STACKS.

The present Convention shall apply to: existing ships which undergo alterations or modifications which the Administration deems to be a substantial variation in their existing gross tonnage. The vessel underwent a major modification in 2006, and the Togo Flag Administration issued a Tonnage Certificate listing the original keel laid date of 1982. See Form B for details. 1969 ITC, Article 3(2)(b).

Cargo ships shall carry at least one rescue boat complying with the requirements of section 5.1 of the Code. The vessel's Safety Equipment Certificate requires one rescue boat. The rescue boat is missing: a buoyant bailer, a sea-anchor, two buoyant rescue quoits attached to not less than 30m of line, a search light, and an efficient radar reflector. 74 SOLAS (14), Ch. III / 31.2, LSA Code 5.1.2.

The condition of the ship shall be maintained to ensure that (it) will remain fit to proceed to sea without danger to persons on-board. Gen. #1 is inoperable. Gen. #2 is missing guards for moving parts and has buckets to catch excessive fuel oil leaks. 74 SOLAS (14), Ch. I/Reg. 11.

The number of openings in watertight bulkheads shall be reduced to the minimum compatible with the design and proper working of the ship; satisfactory means shall be provided for closing these openings. There is a wooden plug separating the starboard aft ballast tank from the main steering gear compartment. SOLAS 74, Ch. II-1/Reg. 13(1).

This regulation shall apply to the following types of ships: cargo ships of 300 gross tonnage and upwards. The vessel is not fitted with LRIT equipment. 74 SOLAS (14), Ch. V/Reg. 19-1.2.1.2.

Ships shall carry a line-throwing appliance of an approved type and shall include not less than four projectiles. Three projectile charges are expired.

Foreign vessels entering U.S. waters from foreign ports are required to submit an Advanced Notice of Arrival. The vessel did not submit an (ANOA). 33 CFR 160, Subpart C.

Unless operating exclusively on voyages between ports or places within a single COTP zone, the crew or vessel representatives must submit a ballast water report to the National Ballast Information Clearinghouse. No report was submitted to the NBIC.

Vessels shall have an up to date IAMSAR Manual Vol. III. The vessel was missing an IAMSAR. 74 SOLAS (14), Ch. V/Reg. 21.2.