NAVAKUN TRANSPORT CO. LTD.

1158/11BANNKRANGKRUNG,BANGNA-TRAD
RD.,BANGNA,BANGKOK 10260

Tel. 02 –182-0388 / Fax 02 - 1820386

Number of pages including cover sheet: 20 pages.

DATE : 14 February 2019

OUR REF : JOB ORDER No. : 2019-0142
TO : Vetting Team.
FROM : Navakun Transport Co., Ltd

Subject : M/T. KHUNKANYA Inspection. (Cargo operation)

***If you do not receive all the pages or they are illegible, please
telephone/inform us immediately ***

Refer to your inspection on “M/T.KHUNKANYA” Date 31 January 2019.

Now I’m pleased to inform you that all of the deficiencies have been complied as
follow;

1 Observations: No Loading Record Book available on board.

(Refer to full report item no.2.40)

Root cause: As our investigation, The master reported, that watch duties cargo officer use
“The Cargo Operation Record" available in SMS company form No.070507, had hourly
detailed record of cargo level/ temperature/pressure gauging include time sheet of the ship.
Which that not covered the details all activity when has the cargo operation.

Corrective Action: The operation team has created the new "cargo load/discharge record
log book" for all vessel in fleet. And assign to marine superintendent went on board to
suggestion all watch duties cargo officers for recording loading/discharge record book.
As a result, the chief officer and second officer further training was proper to be satisfactory.

Preventive Action: Regarding this matter, The operator team had been sent this
observation to informed of all Master of the vessel in fleet acknowledge and correction, with
report back to the marine superintendent for ensure that have not recurrent in next
inspection. Moreover, recheck by marine superintendent during monthly visit plan
Marine Supt. Introduced Cargo officer to recording the cargo loading/Discharge record book.

The cargo loading record. The cargo discharging record.

2 Observations: Found LPG cylinder for hot work kept in locker on port side poop deck
without lashing. (Refer to full report item no. 2.48)

Root cause: As our investigation, Chief engineer inform that observation due to the LPG
cylinder it was forgotten to leave onboard since the ship on last dry dock. Which this LPG
cylinder an empty it is owned by the contractor and them not brought it back after the vessel
completed at dock yard.

Corrective Action: Immediately action, After this inspection completed the LPG cylinder
was lashing by safety officer. On date February 01' 2019 safety officer and ship staff carry
out that LPG cylinder send to ashore for send back to subcontractor in further.

Preventive Action: Regarding this matter, On 01 February 2019 The operator inform
observation strongly recommended to all Ship Safety Officers in Navakun and Khunnavy
fleet to ensure this matter did not occur again. Furthermore, we have assigned Marine
superintendent for strictly checking during on board visits. Fleet circular was launch through
fleet to communicate with all the master of ships regarding this matter.

Before remove LPG cylinder. After removed LPG cylinder to ashore.

3 Observations : The verification hours of rest in hours of rest records were made by
crew themselves not by authorize officer and the signature to confirm the verification
were signed by crew and master prior complete the records.
(Refer to full report item no. 3.6)

Root cause: The work and rest period record (SMS code no. 0609) has in place, but the
master did not to step he signature to confirm the verification were signed the prior complete
the records. And crews member not clearly understand in recording "The work and rest
period record" were made by crews themselves not by the master or authorize officer.

Corrective Action: On 08 February 2019,the marine superintendent went on board and

called all ship staff to pay more attention regarding Procedure hour of rest period (ISM code
no. 0609) for clarify hours of rest records in correctly way. The master should not be sign to
confirm the verification prior completed the records. That in the column of Hours of rest as
applicable in 24 hours period and Hours of rest as applicable in 7 day period should be
additional to calculations and verification by Master or authorize officer. After the master and
crews staff further recommendation by Marine Supt. As a result, That found all crews staff
understand in good order.

Preventive Action: Regarding this matter, The operator sent observation information to
Navakun and Khunnavy fleet. Furthermore, all crews member shall clearly understand
according Procedure hour of rest period (ISM code no. 0609) thoroughly, we have assigned
marine superintendent to instruction during on board visits.

Marine superintendent instruction to signature to confirm the verification record of hour of rest/work.
4 Observations: Found 2 different Drug and Alcohol Policy with 2 different signatures
signed in the same date. (Refer to full report item no. 3.7)
Root cause: Actually since on 18 December 2018, the new "Drug and Alcohol Policy" were
issued and distribute to all the vessel in fleet by the DPA. This observation due to the master
did not replace old D&A Policy with new D&A policy immediately after the master received
that document.

Corrective Action: On 08 February 2019 Marine superintendent went on board to bring the
present Drug and Alcohol policy replaced and posted onboard. Marine superintendent called
to The master and crew staff to pay more attention to document control onboard according
ISM procedure no.1101 at topic 4.1.7 Editing/Document Cancellation/Document Destruction.
However, the old company policy was canceled that bring back to company for destroyed by
DPA in properly.

Preventive Action: Regarding this matter, When management system department had the
documentation up to date. Thereafter, documents were sent on board concern department
rechecked must be contact to all master of ships for rechecked to ensure that all the
document have been sent to the ship timely. This topic was shared to all ships in our fleet.
Moreover, recheck strictly by marine superintendent during monthly visit plan.

There both of old Drug and Alcohol policy was canceled.

The Present Drug and Alcohol policy was replaced and posted onboard M.T.KHUNKANYA.
5 Observations: No navigational and Bridge Organization Manual available on bridge.
(Refer to full report item no. 4.1)

Root Cause: As our investigation, The Master had lacked to check detail in the navigational
and Bridge Organization Manual was post on bridge there not formal document control by
company procedure.

Corrective Action: Immediately action, Marine superintendent went on board and called
Master and crew staff to pay more attention regarding check all documents control if there
were found informal or documents manual instructions onboard. The Master proceeds to
replace the formal Navigational and bridge organization manual have been posted at
wheelhouse properly. This matter was corrective completed on 01 February 2019.

Preventive Action: Regarding this matter, The master should be rejected informal and then
inform to document control officer for support new formal documents to be accurate and
complete. This topic was shared to all ship in our fleet. Moreover, rechecked strictly by
marine superintendent during monthly ship visit.
6 Observations: M.O.B signal on port side bridge wings were installed in wrong
direction. (Refer to full report item no. 5.20)

Root cause: As our investigation, This observation due to the second officer had lacked to
check after installed the M.O.B. signal on port side bridge wing wrong direction. Because of
he did not follow work instruction.

Corrective Action: Immediately action, after the inspection has completed. The marine
superintendent order to second officer was corrective action the M.O.B. signal on bridge
wing at port side in correct direction as per good practice as state in the "SOLAS Training
Manual Book " immediately after completed inspection found in good condition.

Preventive Action: Regarding this matter, The operator had been reviewed of this
observation for preventive repeat this observation to inform of all the vessels in company’s
fleet vessels to advised and explained with this observation to maintained and check all
M.O.B. signal equipment in good condition all the times.

Before, MOB signal installation wrong direction. After, MOB signal installed in correct direction.
 คู่มอื การใช้ งานและบํารุ งรักษา Huahai Marine Signals MFG. Co., Ltd.
Lifebuoy self-ignition light& Self-activating smoke signal.

*คําเตือน*
-ใช้สาํ หรับสัญญาณ ขอความช่วยเหลือคนตกนํ�า เท่านั�น
-ห้ามปล่อย MOB ออกโดยตรงสู่ บุคคลที�ทาํ การช่วยเหลือ
-ใช้ก่อนวันหมดอายุ

(คู่มือบํารุ งรักษา)
1. (อุณหภูมิการเก็บรักษา) ：-30°C～+65°C。
2. (ห้ามโดน ความร้อน และ ประกายไฟ) 。
(HLS-2&HL-2)

1.) การติดตั�ง เปิ ดสวิตช์ MOB ต่อสายเข้ากับห่ วงชูชีพ ยึดน็อต 2.) การใช้งาน ปลดใช้งาน สลักปล่อยเร็ ว ของห่ วงชูชีพ
และใส่สลักนิรภัย ในทิศทางที�ถูกต้อง

3.) พวงชูชีพ และ MOB ต้องร่ วงลงสู่น� าํ โดยไร้สิ�งกีดขวางใดๆ 4.) หลังจากปล่อยห่ วงชูชีพพร้อมเปิ ดสัญญาณ MOB พร้อม
ซึ�งสามารถใช้ได้ในกรณี พบเห็นคนตกนํ�าแล้ว เท่านั�น ทํางาน ให้ เตรี ยมประจําสถานีเก็บคนตกนํ�า

The instruction of Lifebuoy self-ignition light& Self-activating smoke was state in

The SOLAS Training Manual in good order.
7 Observations: Barge did not maintain positive pressure in accommodation, found air-
condition intake was kept open but its packing was lose from the cover and blocked
the air-condition intake. (Refer to full report item no. 5.31)

Root cause: As our investigation, This observation due to cargo officer had lacked to check
according Ship shore safety check list as state in no.45 Positive pressure is being
maintained inside the accommodation.

Corrective Action: Immediately action, The air condition intake packing was replaced by
crew staff properly. The chief officer rechecked air condition intake was found inside the
accommodation is being maintained positive pressure in good order.

Preventive Action: Regarding this matter, The operator team sent this observation inform to
Navakun and Khunnavy Fleet. Furthermore, we have assigned marine superintendent for
strict checking (SMS no.070505 “Ship Shore Safety Check list”) during on board visits.

Before air intake packing replace After air intake packing was replaced
8 Observations: No compressor room entry permit issued prior entry into compressor
room. (Refer to full report item no. 5.51)

Root cause: As our investigation, This observation due to cargo officer had lacked of
compressor room entry permit do not issued prior entry into compressor room.

Corrective Action: Immediately action, Marine superintendent went on board and called all
cargo officer to pay more attention regarding compressor room is required to check it
conditions during both loading and discharging in order to ensure that there was no leakage
or any abnormal such as smoke and damage. Cargo compressor room entry permit and
compressor room condition check record are maintained in order.

Preventive Action: Regarding this matter, The operator sent observation information to all
ship in Navakun and Khunnavy fleet. The operation department is requested to confirm that
cargo compressor room entry permit record is maintained in order as well. Furthermore, we
have assigned marine superintendent for strict checking during on board visits.

Cargo compressor room Entry permit.

9 Observations: Chief Officer was not familiar with the procedures for testing of
personal multi gas meter. The multiple span gas (4 gases) was used for test but only
one kind of gas was recorded and he cannot identify what kind of gas that he
recorded. (Refer to full report item no. 5.46)

Root cause: As our investigation, The chief office lack of familiar with the procedures for
testing of personal multi gas meter. Furthermore, Chief officer not understanding to record
ISM Form.070509 (Oxygen meter/Gas Detector test record.) from company in monthly
testing and calibration of portable gas detector.

Corrective Action: Immediately action, On 08 February 2019, the marine superintendent

called the chief officer and chief engineer (them assign to safety officer on board) regarding
for training and explained to identify kind of 4 gases composite that he recorded
(H2S/CO/O2/LEL%) as follows the work instructions in the manual. Thereafter, testing and
calibration of personal multi gas meter included with record in ISM Form. 070509. However,
thereafter finished training was found Chief officer has familiarization improvement about
responsibility of his duty in good order.

Preventive Action: Regarding this matter, The company superintendent shall be

responsible for the control and monitor, he shall pay attention on visiting vessel at least once
a month in order to check and inspect this equipment for ensure that the equipment is in
satisfactory condition.

The personal multi gas detectors were prepared work instruction to all ship in Navakhun and Khunnavee fleet.
 Personal multi gas meter tested. Oxygen meter/Gas Detector test record.

Observations : The record of water ballast tanks inspection had no details of

10
condition of tank’s structural but only coating and fitting in the tanks (Refer to full
report item no. 7.3)

Root cause: As our investigation, The chief officer lack of recorded specific details of
condition of tank’s structural in the record of water ballast tanks inspection as state in deck
department maintenance plan according ISM procedure.

Corrective Action: Immediately action, On 02 February 2019 Marine superintendent went

on board and called all ship staff conduct to check for all water ballast tanks inspection
include details of condition of tank’s structural but only coating and fitting in the tanks and
record in the form “Tanks Inspection" was found all of the water ballast tanks condition in
satisfactory.

Preventive Action: Regarding this matter, The operator are assignment to Marine
superintendent to cross check during ship’s visiting and send of this observation to inform of
all ships in the fleet to Navakun and Khunnavy Fleet remind.
FPT. inspection record BWT no.1 inspection record
The record of the water ballast tanks inspection.
11 Observations : Company Ship/Shore safety checklist used on board was not complied
with ISGOTT (Refer to full report item no. 8.2)

Root cause: As our investigation, This observation due to the inspector suggestion to the
master include ship operator was found Company Ship/Shore safety checklist used on board
was not complied with ISGOTT as state in Ship/Shore Safety Check-List
Part ‘B’ – Bulk Liquid General – Verbal Verification.
45. Positive pressure is being maintained inside the accommodation, and air conditioning
intakes, which may permit the entry of cargo vapours, are closed.

Corrective Action: Immediately action, The operator informs this observation to Designed
person revision process for the Ship/Shore safety checklist. Which the Designed person
announced and commitment that. The date on 11 February 2019 New revised Ship/Shore
safety checklist was complied with ISGOTT should be implementing on board to all ships in
Company fleet completely.

Preventive Action: Regarding this matter, The operator preparation to sent circular
information to Navakun and Khunnavy Fleet. Furthermore, the entire crew understood
thoroughly. We have assigned marine superintendent to introduce New revised Ship/Shore
safety checklist with cargo officer during on board visits and in house training will be carried
out in monthly for improving the knowledge of crews in Navakun and Khunnavy Fleet.
12 Observations: No written agreement of maximum loading rate and maximum
discharge rate available on board. (Refer to full report item no. 8.3)

Root cause: As our investigation, The chief officer lack of written agreement of maximum
loading rate and maximum discharge rate according to “Discharge plan agreement’’ as per
company SMS check list no. 071104.

Corrective Action: Immediately action, Marine superintendent went on board had strongly
recommended to the master and cargo officer to pay more attention on all cargo work
documents, and they must be checked correctly before make their signature. However, the
cargo work documents will be sent to office at finished voyage in order to monitor this
measure will be make sure that our ships personal will be in understanding on duty of cargo
operation in correctly.

Preventive Action: Regarding this matter, The operator sent observation info to Navakun
and Khunnavy Fleet. Furthermore, we have assigned Marine superintendent for strict
checking “Discharge plan agreement’’ as per company SMS check list no. 071104. During
monthly on board visits.
13 Observations: Two indicator lights of cargo monitoring system panel located on
bridge were not lit. (Refer to full report item no. 8.19)

Root cause: As our investigation, the third engineer had lacked to check and maintenance
the indicator lights of cargo monitoring system in the good condition in accordance
As state Company of Plan maintenance. This requires a cargo monitoring ALARMS system
must be check and test include function of indicator lights with buzzer in monthly period.

Corrective Action: Immediately action, the technical superintendent attend with the Chief
engineer to onboard investigate about this matter was found that caused by effected of
tremble to indicator lights were broken. As a result two indicator lights of cargo monitoring
system panel located on bridge were not lit during tested. They then, replaced two indicator
lights were tested and recheck found that all in functioning of cargo monitoring system
properly.

Preventive Action: Regarding this matter, On 08 February 2019 Technical Superintendant

went on board and strongly recommended to all ship engine staff to maintain all indicator
lights of cargo monitoring system are in good condition at same time and proper
maintenance in accordance with PMS. More over this topic was shared to all vessels in our
fleet as well.
 The Company of Plan maintenance. This requires in monthly test a cargo monitoring function as above mention;

14 Observations : Test record of high level alarm, low level alarm, high pressure alarm
were inspected and found it were tested every voyage prior cargo operation. Chief
officer was interviewed and found only indicator light and buzzer at control panel
were tested and he cannot explain how to test the high level, low level and high
pressure alarm (Refer to full report item no. 8.73)

Root cause: As our investigation, Chief office lack of familiar with that matter. How to test
the high level, low level and high pressure alarm of cargo monitoring system.

Corrective Action: On February 09’ 2019 Marine superintendent attend to the shore base
technician from "PASITA Electric Limited Partnership" conduct on board of the ship to
provide further training to the chief officer as following.
Implement testing cargo monitoring system of personal multi gas meter included with record
-High level alarm, low level alarm
-High pressure alarm, low pressure alarm
-High temperature alarm, low temperature alarm
However, thereafter finished training was found Chief officer has familiarization improvement
about responsibility of his duty in good order.

Preventive Action: Regarding this matter, The operator sent observation information to
Navakun and Khunnavy Fleet. Furthermore, the entire crew understood thoroughly. We have
assigned marine superintendent to check strictly during on board visits and in house training
will be carried out in monthly for improving the knowledge of crews in Navakun and
Khunnavy Fleet.
15 Observations: All deck officers included superintendent confirmed slip tubes were
used for final gauging for cargo calculation in every voyage.
(Refer to full report item no. 8.81)

Root Cause: As our investigation, Limit of operate the slip tubes while in cargo operation
was posted in mess room and on cargo tank dome. But the slip tubes of the cargo tanks to
use for confirm cargo levels in the final stage as agreement accepted by terminal and Excise
Department.

Corrective Action: Immediately action, On 08 February 2019 marine superintendent

attended meeting on board of the ship to advise the master and cargo duty watch keeping
officers that the slip tubes are generally used only in cases of emergency. A small amount
of cargo vapor or liquid is released in the air during level measurement. Therefore, this
devices must not be use when toxic cargoes are carried and in the case of flammable
cargoes. Only if permitted by the terminal or the charterer. As a result, the master and all
cargo duty watch keeping officers of the ship were found well understood and will follow the
procedure with intention.

Preventive Action: Regarding this matter, The operator sent observation information to
Navakun and Khunnavy fleet. Furthermore, all crews member shall understand thoroughly,
we have assigned marine superintendent to instruction during on board visits.
 The above observation items and corrective actions have been distributed to
all vessels in our fleet for prevent the repeat failure. Any information do not
hesitate to advise us, we will pay best attention on your advices.

Note: After inspection finish we started corrected immediately form 1 February

2019 and complete on 13 February 2019.

Thank you very much for your kind consideration to accept our rectification.
Best regards,

Mr.Runayuth Suriyawong.
Marine superintendant.
Tel: 098-2516325