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Page 1 of 7 1.0 Introduction 2.0 Responsibility 3.0 Procedure 4.0 Record Retention Times 5.0 Obsolete Documents Revision/ Review Log Revision Date Approved by Reviewed by Revision Details/ Proposal Notes 11 January 2010 HSE Manager: Sue McDonald Revision #5 25 Oct 2010 Revision #6 25 Oct 2010 Revision #7 09 Dec 2010 Revision #8 25 February 2011 Revision #9 HSE Manager Designee: Capt. Pat Fallwell HSE Manager Designee: Capt. Pat Fallwell HSE Manager Designee: Capt. Pat Fallwell Changed to electronic format Changes to document control due to conversion to electronic docs No need to acknowledge Notices of Change Chapter further revised to fit new electronic format of controlled document (SMM) 28 March 2014 Revision #10 Dr. Roger Fay Vanuatu publications added 08 September 2014 Revision #11 SMM returned to paper format 30 January 2015 Revision #12 Retention times for ship forms set at 2 years 16 February 2016 Revision #13 Dr. Roger Fay Obsolete documents addressed, publications clarified by requiring agency 11 August 2016 Revision #14 Dr. James Howell How changes are processed and documented outlines

Page 2 of 7 04 October 2016 Revision #15 Dr. Roger Fay Dr. James Howell Record retention time updated to reflect Vanuatu requirements of 3 yrs 1.0 Introduction Current company controlled documents are kept in paper format and are: Safety Management Manual (SMM) Standard Operating Procedures (SOPs) Revisions to our controlled documents will be managed through a system of reviews, approvals and e-mail notifications. 2.0 Responsibility for Controlled Documents It is the responsibility of the HSE manager or his/ her designee to notify the fleet and affected personnel of any changes and revisions to controlled documents. The HSE manager must also ensure that any changes are reviewed by appropriate company experts for accuracy. It is the responsibility of the Master to ensure that all ship s officers are familiar with controlled documents as well as any revisions. It is the responsibility of the Party Chief, Master and Chief Engineer to be familiar with controlled documents and the Safety Management System. 3.0 Externally Generated Documents Externally generated documents (EGD) include certificates, publications, and reports required by different conventions, regulations, and administrative authorities. Original certificates are issued to and maintained on the vessel in a File. Scanned copies of these are provided to the office and maintained on the Crewing Module in electronic format that can be accessed from anywhere thru the internet. Evidentiary documents and logs are kept in original hard copy on the vessel, and electronic (scanned) copies of some are retained in the office or on the Crewing Module. These include the following for the US uninspected vessel and the vessels of Vanuatu Registry:

Page 3 of 7 Key: = required = vessel has but not required Voluntary= not required but TDI has voluntarily complied N/A= Not applicable Required/Issued By USCG ORV (Brooks McCall) Vanuatu Flagged Vessels SHIP SPECIFIC CERTIFICATES AND DOCUMENTS Bridge to Bridge Radio License Flag Admin. N/A of Documentation Flag Admin. (Registry) International Tonnage Tonnage Convention Article 7 ORV Designation Letter Flag Admin. N/A Radio Station License Flag Admin. Regulatory Tonnage Flag Admin. Antifouling Systems N/A Cargo Ship Safety 1988 SOLAS protocol reg I/12 N/A (<500 GRT, and pre 1984) (2000 Amendments,) appdx Cargo Ship Safety Construction 1988 SOLAS Protocol reg I/12 N/A (>500 GRT) Cargo Ship Safety Equipment 1988 SOLAS Protocol reg I/12 N/A (>500 GRT) Cargo Ship Safety Radio 1988 SOLAS Protocol reg I/12 N/A s for Masters, Officers, STCW 1978, STCW Code A-I/2 Ratings Class N/A Continuous Synopsis Record SOLAS reg XI-1/5 N/A (CSR) DMLC Parts 1 & 2 Maritime Labor Convention N/A Voluntary Document of Compliance SOLAS reg IX/4, ISM Code Fire Control (Fire/Safety) Plan SOLAS 1974 (2000) Fire Safety Training Manual SOLAS 1974 (2000) Garbage Management Plan MARPOL 73/78 Annex V, reg 9 Garbage Record Book MARPOL 73/78 Annex V, reg 9 GMDSS Shore Based SOLAS IV reg 15 N/A Maintenance Agreement ILO MLC 2006 Maritime Labor Convention N/A Voluntary Insurance Liability Flag Administration Bunker Blue Card (convention Not Applicable) N/A

Page 4 of 7 International Air Pollution MARPOL 73/78 Annex VI N/A Prevention International Energy Efficiency 1997 Protocol, MEPC.203(62) N/A International Load Line LL Convention International Oil Pollution MARPOL 73/78 Annex 1, reg 5 N/A Prevention International Sewage Pollution MARPOL 73/78 Annex IV, reg N/A Prevention 5, MEPC/Circ 408 International Ship Security SOLAS reg XI-2/9.2.2 N/A ISPS Code Log of Ozone Depleting MARPOL 73/78 Annex VI N/A Substances (IAPP Supplement) LRIT Conformance Test SOLAS V reg 19-1 N/A Minimum Safe Manning SOLAS reg V/14.2 Document Non- Tank Vessel Response Plan 33 CFR 155 (NTVRP US waters only) Oil Record Book MARPOL 73/78 Annex 1, reg 20 On Board training and drills SOLAS 1974 (2000) Record Safety Management SOLAS reg IX/4, ISM Code Ship Security Plan and SOLAS reg XI-2/9.2.2 associated Records ISPS Code SOPEP (Shipboard Oil Pollution MARPOL 73/78 Annex 1, reg Emergency Plan) 26 Stability Book/letter 1988 Load Line Protocol Reg 10 Port State Control Inspection Flag Administration Reports External & Internal Audit ISM Code Reports of Safety Management System External & Internal Audit ISPS Code N/A Reports of Vessel Security System/Plan Annual Safety Inspection Flag Administration N/A Reports Survey Report File

Page 5 of 7 Other externally generated documents (both required and voluntary) include publications, legislation, rules, guidelines, and other sources of information useful to the operator and mariner. These are provided to the vessel in hard copy and/or electronically on CD. Periodic updates are sent to the vessel via CD when they become available. Regular periodic updates of an essential nature (like Notice to Mariners - http://www.ukho.gov.uk/productsandservices/martimesafety/pages/nmpublic.aspx) are obtained directly by the vessel crew via the internet. PUBLICATIONS AND LOGS REQUIRED, AND USEFUL IN BEST PRACTICE Required/Issued By USCG ORV (Brooks McCall) Vanuatu Flagged Vessels cd 33 Code of Federal Regulations Flag Admin. cd 46 Code of Federal Regulations Flag Admin. Chart Catalog cd COLREGS International Regulations for Preventing Collisions at Sea 1972 Flag Admin. Garbage Record Book Flag Admin. cd IMSAR Manual Vol III SOLAS V, reg 21 cd International Code of Signals SOLAS V, reg 21 International Health Regulations International Medical Guide for Ships ISM Code, Safety Management SOLAS reg IX/4, ISM 2014 Code cd ISPS Code, Ship and Port SOLAS reg XI-2/9.2.2 Security ISPS Code cd Life Saving Appliances Code cd Life Saving Rescue Signals SOLAS V, reg 29 cd Light Lists SOLAS V, reg 27 List VIIA- Alphabetical list of Call Signs and Identity of Stations cd Load Line Convention 1966 Flag Admin. Manual for Use by Maritime Mobile and Satellite Services cd Maritime Labor Convention 2006 ILO MLC

Page 6 of 7 cd MARPOL 1973/78 Medical Log Book Navigational Charts (for SOLAS V, reg 27 routes) Official Log Book (flag state) Flag Admin. Oil Record Book Flag Admin. cd Pub 117 Radio Aids to SOLAS V, reg 27 Navigation cd Sailing Directions SOLAS V, reg 27 cd SOLAS 1960 (as applicable) cd SOLAS 1974/78, amended 2009 STCW 95, & Manilla Amendments Tides and Currents SOLAS V, reg 27 Vanuatu Articles of Agreement Flag Admin. or Seafarer Employment Agreement cd Vanuatu Fisheries Act Flag Admin. cd Vanuatu Maritime Act Flag Admin. cd Vanuatu Maritime Bulletins Flag Admin. cd Vanuatu Maritime Regulations Flag Admin. cd American Practical Navigator cd Beaufort Scale cd Bridge Procedures Guide cd Code of Safe Working Practices for Merchant Seamen cd IAGC Safety Manual cd Revised Procedures for Port State Control 2011 cd USCG Marine Safety Manual 4.0 Responsibility for Externally Generated Documents It is the responsibility of the Compliance Manager to ensure that all appropriate Externally Generated Documents (EGDs) are current and distributed to the vessels and office as appropriate.

Page 7 of 7 5.0 Procedure Any suggestions for changes to a controlled document must be submitted to the HSE Manager in writing. Suggestions may be submitted in the form of Master s Reviews, Safety Cards or direct personal email. The HSE Manager is responsible for investigating suggested changes and involving competent persons in the changes and final review. All changes must be approved by the DPA. Changes are then communicated to the fleet through Notices of Change (NOCs), which are posted on the Crewing Module. 6.0 Record Retention Times Per Vanuatu Fleet/ Safety Letter 2016-August-10, all log books must be retained on board for 3 years, except in the case of a Major Marine Casualty which will necessitate the records of the time frame 3 months prior and 3 months after the casualty being kept on board for a period of 5 years. 7.0 Obsolete Documents The Chief Mate of the vessel is responsible for removing obsolete documents from the SMM and updating any related postings on the vessel. The Party Chief is responsible for removing project specific documents/ postings (client s safety posters, project specific emergency plans, contact lists) at the end of the project.