Technical Department

Marine Circular 022 TEC REV 01/ 16.03.2017 Novaveritas NV Safimar Inc. Technical Department FROM: TECHNICAL DEPARTMENT TO: to all NV Surveyors & Auditors and technical personnel DATE: March 24, 2017 SUBJECT: Findings & recommendations from documental review and to be reported during internal audit process and or inspection as a mandatory requirement General Requirements Auditors should comply with mandatory Guideline for Findings & recommendations during internal audit process and should be guided by the DOC NVSA 02 DOCUMENTAL NON-CONFORMITIES which offers a familiarization with the issuance of non-conformities when auditors conduct the document review. Non-compliance will be considered a lack of familiarization with customer`s requirements, and some our customers could refuse accept the reports. This guideline is a mandatory procedure for all attending auditors conducting HSSEQ Services on behalf of NOVAVERITAS NV - SAFIMAR INC. Technical Department Page 1 of 1 Inquiries concerning the subject of this circular should be directed to info@novaveritasaudits.com

Página 1 de 9 Familiarization whit the issuance of documental non-conformities 1. Introduction The objectives of the ISM Code a e to e su e safety at sea, p e e tio of hu a i ju y o loss of life, and avoidance of damage to the environment, in particular to the marine environment and to p ope ty. I M Code.. Compliance of this is a requirement, and means that the Company (owner or any organization or person or bareboat charter who has assumed the responsibility for operation or the ship from shipowner ISM Code 1.1.2) should adopts many measures to get these objectives. Among others: a) provide safe practices in ship operations and safe working environment; b) identify risks; c) improve safety management skills of personnel ashore and onboard, this mandatory requirement includes preparation for emergencies (for example, training and drills) and safety and environmental protection (for example, training, drills, resources, maintenance, planning, etc.). In this way, as per ISM Code 1.2.3. the Safety Management System should ensure: a) compliance with mandatory rules and regulations (SOLAS, MARPOL, MLC, STCW, IMSBC Code, FFS Code, WHO, etc,); and, b) applicable codes, guidelines, standards recommended by the IMO, Flag States, Classifications societies, marine industry (BIMCO, IACS, P&I, etc.) should be taken into account. According to ISM Code there are three kind of findings: 1.1.8 Observation; 1.1.9. Non-conformity; 1.1.10 Major non-conformity. (Definitions of each can be reached at the last version of The ISM Code), however any of these findings should be substantiated by objective evidence. If it is not possible to provide substantiated objective evidence, then there isn t a Non-conformity, but could be an observation to investigate more. INTERNAL AUDITS are conducting using a quite different methodology, because each company is looking for different aspects of compliance: strict fulfillment with the ISM Code, general condition of the vessel, organization of each department onboard. During internal audits, for instance, deficiencies found are objective evidence for singles nonconformities: each deficiency sometime is a non-conformity see our PRO TEC Pro edures for fi di gs. But hat happe ed ith do u e t re ie? It is very common to listen from auditors who are also inspectors the following comment: this vessel has been recently delivery, it is a new construction, so I will not find any non-co for ity this is a very common commentary and also is a big, big mistake. The reason, is very simple: What could be happened with document control? There are many concerns about this, and you, as auditor, should satisfy all concerns regarding this: The vessel should comply with requirement for each relevant document as a part of the Company Quality Management System.

Página 2 de 9 WHY? Because lack of effective document control may lead non-conformities and may leads serious marine casualties. Thinking about it! The Company Management System of a company requires that before entering a closing space the officer on duty fill a form to determine if the crew has followed all steps to prevent any injury and reduce the risk entering such enclose space. FACT 1 due different reasons the officer on duty didn t fulfil with the requirement to answer all blanks at questionnaire. Some of these blanks advice about the compliance with critical steps. FACT 2 One normal day, the officer on duty fill the form, but forgot to complete totally. He obviates to check the box where the system required to test the Portable Oxygen Concentration Content Tester Meter Detector prior to enter an enclose space. FACT 3 The AB on duty and the 3 rd Mate, both commissioned for the task, entering and both were wearing full P.P.E., once inside they turned on the Tester and equipment shows acceptable atmosphere condition. FACT 4 After 5 minutes, none of the seafarer working inside the tank reported activity. The officer on duty decides to go inside and check. He noticed that both crew members were passed out. The ship started a rescue procedure and both crew members were rescued unharmed. CONCLUSION: After an investigation, the analysis of the root cause revels that many forms onboard were managed in lazy manner. If the Officer on Duty were followed the procedures and filled the form as required, this incident has never happened. This is the reason why DOCUMENT REVIEW is so important. A vessel could be new construction, or maybe could be well maintained, but there are obscure situations that not easily arise, but a good auditor can find though a careful revision of document.

2. Non-conformity DOC NVSA 02 DOCUMENTAL NON-CONFORMITIES Página 3 de 9 ISM Code 1.1.9 defines a Non-conformity as a o se ed situatio he e objective evidence indicates the non-fulfilment of a specified requirement. ISO 9001:2015 defines a Non-conformity as a o -fulfillment or failure to meet a e ui e e t. A requirement is a need, expectation, or obligation. It can be stated or implied by an organization or interested parties. Major non-conformity means a ide tifia le de iatio that poses a se ious th eat to the safety of personnel or the ship or a serious risk to the environment that requires immediate corrective a tio (ISM Code 1.1.10). Following with our example: in this case, the incorrect filling of forms is a MAJOR NON- CONFORMITY. 2.1 How to write a Non-conformity The purposes for writing a nonconformity are: (a) To establish evidence of a problem discovered, and (b) To provide the information so that the problem can be corrected. Non-conformities require three stages to be a well-documented Non-conformity 1. objective evidence (to support auditor findings) What you see, what you heard, what you read. You must write down your evidence. (In some cases, objective evidence can be supported by pictures, videos, audio, photocopies, etc.). 2. Requirement (against which the Non-conformity is detected) You have the evidence, but what is the applicable criteria to determine this: Could be, among others, SOLAS, MARPOL, CLASS RULE, FLAG STATE REGULATION, COMPANY PROCEDURE, COMPANY POLICY, CUSTOMERS REQUIREMENT, PORT FACILITY REGULATION, etc. You must include the actual requirement, which will typically be the exact clause of Code or Regulation that is in violation. Additionally, applies the ISM Code 1.2.3.2. 3. Rational writing of the violation (the statement of the Non-conformity) This means that your Non-conformity must be brief, one-sentence statement, to DETERMINE why this objective evidence violates the requirement. It must be selfexplanatory and be related to the system issue. REF: http://isotc.iso.org/livelink/livelink/fetch/3541460/17530839/apg- DocumentNonconformity2015.pdf?nodeid=17524997&vernum=-2

3. Examples DOC NVSA 02 DOCUMENTAL NON-CONFORMITIES CASE 1 Co pa : Tulip e porti g group I. Criteria: Página 4 de 9 a) Quality Management Policy: Clause V We export red tulips only, our tulips plantations guara tee fi e red tulips b) Procedure TEG 0143 states i.. Our pla tatio s ill ulti ate red tulips o l During the audit at visiting the garden of red tulips the auditor observes this: The auditor wrote the following non-conformity: a) NC: The product does not comply with requirement states on QMP Clause V amd Procedure FEG 0143 Clause 2.4.3. b) Objective evidence: During the plantation tour was observed that one of the flowers was yellow. c) Requirement: QMP Clause V; Procedure FEG 0143 Clause 2.4.3. CASE 2 Co pa : Flo ers e porti g group I. Criteria: a) Quality Management Policy: Clause 6 We export tulips only, our tulips plantations guara tee fi e tulips b) Pro edure FEG states i.. Our pla tatio s ill ulti ate tulips o l During the audit at visiting the garden of red tulips the auditor observes this: In this case, there is no Non-conformity, because according to audit criteria: QMP Clause 6 and Procedure FEG 105 Clause 2.2.3, company just cultivates tulips, regardless the color.

CASE 3 Incorrect filling of forms: Non-conformity or Observation Página 5 de 9 Forms themselves have instructions for filling, a form when designed considers some areas to be checked after the evaluation or review of the requirement. Normally one form will be fully completed, unless exceptions are specified. In case a part of a form is not completed, it is good practice to leave a record of the reason why this part has not been completed. Incorrect filing of forms could be identifying as a Non-conformity, major Non-conformity o just an observation. For instance, the auditor checks engine records for the last 2 month, and see that not all form recorded to authorize hot ork per it (DOC 001) has been signed by Chief Engineer (at least 3 of 40). This is only an observation because it is not a systematic practice, however should be reported because engine department need to find the root cause. During the same document review, the auditor noticed that records for ha geo er of unattended machinery spaces DOC report are not completed in full, this is repeated during afternoon checking and during 25 days of each month. In this case this a non-conformity, because show a systematic deviation from the criteria. But, before to write the Non-conformity, the auditor need to ask if there are any written procedure or instruction for filling this form here the auditor is looking to clarify if this finding is a deviation or not. There are to possibilities, like the flower case: a) Possibility 1 - The o pa ha e a ritte pro edure hi h state that i spe ifi ases this for ust ot e totall o pleted a d gi e a list of these ases. In this case, the finding is not a Non-conformity nor and observation, because the criteria allow to let some areas in blank under specific circumstances. The auditor must check if any of these circumstances happens. b) Possibility 2 There are not any instruction nor procedure for filling the form, so in this case the form themselves is the procedure to fill it. As there are many forms not totally filled, then the auditor write a Non-conformity as follows: Non-conformity: During engine document review was observed that not all DOC 002 have been filled as required. Objective evidence: Record of Form DOC 002 from Nov 01 st, 2016 to Dec 14 th, 2016 has been examined and at least the 85% have been found incomplete or filled not as required. Requirement: ISM Code 11.1 The Company should establish and maintain procedures to control all documents and data which are relevant to the safety management system.

CASE 4 - Requirement: (Criteria) DOC NVSA 02 DOCUMENTAL NON-CONFORMITIES Flag State regulations requires that all Officer be in position of STCW endorsement. Página 6 de 9 STCW 2010 as amended requires that National Certificates be endorsed by the Flag State Administration which flag is entitled to fly for the ship. Finding: 2 A.B. and 4 th Engineer have national certification only. Investigation: Auditor check that those crewmembers be qualifies as required by the type of ship and all be in position of valid national certificates. After that write a non-conformity: NC: During the document review was observed that not all crewmembers were in position of vessel s Flag State endorsement. Objective evidence: 2 A.B. and 4 th Engineer have not vessel s Flag State endorsement. Requirements: Flag State Regulations STCW 2010 Convention. 4. The three parts of a Non-conformity Review 2.1 www.iso.org/tc176/iso9001auditingpracticesgroup a) The audit evidence b) Record of the requirement c) The statement of Non-conformity The audit evidence The requirement The statement of Non-conformity

Página 7 de 9 5. What to look for and where Few examples What to look for Filled forms must be filled completely Ask for procedures for welding, enclose spaces entrance, afloat work, etc. and then compare records. Crew STCW certificates must be endorsed by Flag State Officers must be qualified as per ship s type and requirement as per STCW 2010 Medical certificates must be valid and originals Ship Security Officer Endorsement Policies posted must be updated versions Documents must be completed accordingly to instructions Certificates updated Previous Non-conformities must be closed And analysis root cause investigated. Certificate of calibration for critical equipment must be available Publication must be updated (Check on IMO.org publications list) Loog books must be completed as required others Where to see Engine records Bridge records Deck records Work permits Officer and ratings STCW / MLC folder Officer and ratings STCW / MLC folder Officer and ratings STCW / MLC folder SSO STCW / MLC folder Walls, ship s records Planned maintenance system Ship s certificate folder Last internal audit Last external audit Port State Control report Flag State Report Engine, deck folders Vessel library Bridge, engine room others

Página 8 de 9 According to the criteria of use, which is stated in the same form, e losed spa e e tr permit is valid during or al orki g da. However, this records shows that the permit has been issued from 10:00 10/05/16 to 17:00 11/05/2016 (more than normal working day of 8 hours)

Página 9 de 9 Responsible person signature is missing 6. Conclusions Documental review can be a source of obscure deviations not easily noted for the crew, so the mission of the Auditor is to find these deviations and issue the Non-conformities or notify about observations. Non-conformities are a powerful tool to maintain the effectiveness of the management system and to lead to the continuous improvement. Date Revision Attesting Authorized by 23.03.2017 0 Original CEO