1.1. CONTROL OF NON CONFORMANCE (NC), ACCIDENTS / INCIDENTS & CORRECTIVE ACTION & PREVENTIVE ACTION

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1 Chapter : FOM-9.1 Page : 1 of CONTROL OF NON CONFORMANCE (NC), ACCIDENTS / INCIDENTS & CORRECTIVE ACTION & PREVENTIVE ACTION PURPOSE To ensure that any services, equipment, materials, personnel, procedures or operating instructions which do not conform to the specified requirements of the SMS / Company are not allowed to be used or installed To provide for the analysis of all non-conformances (NC), monitor any pattern which may be evident and initiate appropriate CA to prevent recurrence of NC in the SMS To learn from the Accidents/Incidents and mistakes of others and take Preventive measures to avoid similar accident/incident occurring within the organization SCOPE This procedure describes the activities and controls required to ensure that NC are identified, recorded and disposed and effective corrective and preventive actions is taken in order to maintain Safety operations both ashore and onboard each vessel RESPONSIBILITY The DPA is responsible for keeping record of all NC,accidents/incidents, evaluation of same and ensuring that corrective/preventive action are timely taken The DPA is responsible for carrying out the root cause analysis and taking effective CA and ensuring such action is effective The root cause analysis should be carried out and completed within 20 days from the date the NC has been initiated All personnel shore based as well as the shipboard staff are responsible for identifying and reporting any incident / Accident happening to their senior officer The DPA is responsible to document the Near Miss / Incident / Accident reporting.

2 Chapter : FOM-9.1 Page : 2 of PROCEDURE Authority to Raise a Non-Conformance All personnel at this office and on board all the vessels have the authority to identify any Non conformity that could be seen and identified by the person He shall report the same to the head of the department who in turn will raise a Non-Conformance. The NC form will be filled up only by the HOD The originator (person identifying a non-conformance) is required to bring it to the notice of the HOD the details and nature of the Non conformity The HOD will then fill in a Non conformity form The person raising a Non conformity is usually termed as the AUDITOR and the person upon whom the non conformity is raised is the AUDITEE The completed Non-Conformance form shall be signed by the person who RAISED the non conformity as well as the responsible person directly related/ responsible for the area / system related to the non-conformance for acknowledgement and acceptance of the non conformity An evaluation of the non conformity is done by the AUDITOR to access how long should the AUDITEE take to close the Non conformity and a time frame is agreed upon by the auditor and the AUDITEE Such completed form with the planned action agreed is submitted to the DPA The AUDITEE will take an immediate action upon the receipt of the non conformity and this immediate action is termed as CORRECTION, not to be confused with the CORRECTIVE ACTION. This immediate action is to get going an immediate action so that the non conformity is removed. Example some check list is not filled up as a requirement of the system immediate action the check list is filled up or signature done is only a temporary action or an immediate action termed as correction to the problem. A corrective action is incomplete without a ROOT CAUSE ANALYSIS which is done after the correction.

3 Chapter : FOM-9.1 Page : 3 of A Root cause analysis is done by the Auditee and a proposed action plan is submitted along with the action taken in line with the root cause analyzed The Action is completed for the Non conformity not to reoccur again as a part of corrective action and verification of the action is observed for a while not to reoccur again before submission of the completed action to the AUDITOR Once satisfied that the action is effective the Auditor may close or authorize to close the NC to be verified at a later date or in case of an audit the next audit All completed actions and closure of the NC is done by the DPA Role of the Master on board the vessel: Master shall instruct head of each department to submit report on non-conformities, accidents and hazardous occurrences taken place in their respective departments as when it occurs.(report format # FOM 9.1A for Non Conformance/ 9.1B for Accident / Incident report and 9.1C for incidents as a near miss report The Master will take appropriate measures to ensure that the same incident or the Non conformity does not take place again to reoccur The Master shall submit the report vide form # FOM 9.1A/9.1B/9.1C AS APPLICABLE and submit to the DPA DPA shall review the action taken and if required advises the Master to take further action and in case of some incident which should be prevented from occurring on board other vessels will be flashed to all other vessels as a preventive action circular or a safety bulletin. ( Refer action by DPA) If any amendment is required in SMS document, the same shall be initiated by the DPA and the revised document is distributed as per FOM This report is discussed in the Management review meeting in the office as well as in the monthly safety committee meeting on board the vessel Accidents / Incidents / Hazardous Occurrences: It is essential that the Company is kept fully advised of any accidents /Incidents and hazardous occurrences, as described here below.

4 Chapter : FOM-9.1 Page : 4 of Whilst appreciating the demands upon ship's staff in case of such serious incidents, it is vitally important that the Company receives a certain amount of basic information as soon as possible after the incident has occurred Personal Injury Reporting Personal Injury means any contingency whereby there is loss of life or major injury to any person on board, or any person is lost from a ship. The Master is responsible to ensure that the office is notified about the incident as soon as possible. The initial report should contain any of the following information which may be relevant to the incident. Reporting can be carried out either by telex or equivalent report. PERSONAL INJURY REPORT AA BB CC DD EE FF GG HH Release Of Oil Name of ship Person injured, name, and rank Date and time of accident Details of injury Brief details of how accident occurred Description of treatment given on board Ship's intention/actions to arrange medical treatment Any assistance required Whenever there is a release of oil from a ship's hull or pipeline system, or if a ship is accused by a terminal or local authority of having caused a pollution, the Company must be advised immediately. This report is required regardless of whether or not any oil actually enters the water. The initial report must be in the format specified by the vessel's SOPEP. Further more Master's are reminded of their obligation to report such incidents to the local authorities as specified in the SOPEP Other Accidents & Hazardous Occurrences All instances whereby the safety of a ship has been under danger shall be reported to the office. Such cases can include accidents (collision, grounding, fire, explosion, parting of mooring lines etc.) or other incidents which under different circumstances could have led to an accident (i.e. near miss, explosive atmospheres, loss of power, etc.). The initial report should include any of the following data which may be

5 Chapter : FOM-9.1 Page : 5 of 7 relevant to the incident. Reporting can be carried out either by telex or equivalent report. AAA BBB CCC DDD EEE FFF GGG HHH III JJJ KKK LLL MMM NNN OOO PPP Ships Name Ships Position (Lat. and Long) Time and Date of Incident (GMT) Type of Incident Injuries to personnel Damage to the ship Condition (stability, power, steering) of the ship Action taken by ship Any further action planned Any other assistance available on site Weather conditions Set and drift of the ship Ships proximity to other hazards Which third parties informed Local P&I informed Any Other Relevant Information - e.g. assistance required, ships in vicinity All accidents that occur on board the vessel involving the following are to be reported to the Flag Administration so that the office can take effective cause analysis and this can prevent future accidents on other vessels. ACCIDENT INVOLVING: I. EXPLOSION II. FIRE III. DEATH IV. MAJOR INJURY V. CAPSIZE OF A POWER-DRIVEN CRAFT OR BOAT, OR VI. POLLUTION CAUSING SIGNIFICANT HARM TO THE ENVIRONMENT Record Keeping Log Extract The Master shall be responsible for forwarding of log extracts to the Manager Log extracts shall be a verbatim record of the original entry in the log book. (including punctuation marks).

6 Chapter : FOM-9.1 Page : 6 of "Log Extract Doc No. FOM 9.1 D shall be sent to the Manager in triplicate, duly signed and stamped by the Master and Head of Departments Log extracts are to be sent when any of the following events occur : When there is any injury to person (s); Crew sign off on medical grounds - sickness or injury; In all cases of death on board; Upon collision or contact with other craft or vessels (including tugs, pilot vessels, fishing boats etc.); Upon collision causing damage to shore installation or fairway marks (wharves, cranes, buoys etc.); When damage has been caused by assisting tug boats on own ship or 3rd person's property; When damage has been caused to third person's property by the use of ship's (anchors, booms, moorings, ramps, cranes etc.); In all cases where pollution has been or suspected to have been caused by the ship. (oil, sewage, garbage etc.); When damage to own ship and/or its equipment has been caused by persons other than ship's crew (stevedores etc.); When damage or significant deficiency has occurred to cargo; In cases of theft from the ship's stores or equipment; In all cases when stowaways are found on board; Loss of lubricants, bunkers, provisions and stores in connection with an average; When damage caused to own ship will involve repairs under general or particular average When it is not possible to assess damage caused to own ship and the cost of repairs to rectify them as a result of an accident due to the peculiar circumstances and location for e.g bottom damage, heavy weather or ice damage When an accident results in a delay of some duration in port or a prolongation of the voyage The Master shall maintain all log extracts for a period of not less than three years unless specific instructions are received from the Manager in view of any pending claims Follow Up Ship staff shall provide a follow up report to Mumbai Office, by the fastest possible means, outlining all action taken and suggestions for future preventive action. All accident and hazardous occurrence reports received in Mumbai Office shall be forwarded to the D.P.A. The D.P.A. is responsible to:

7 Chapter : FOM-9.1 Page : 7 of Ensure that all such incidents are followed up by the company and any necessary assistance is provided to the ship Review and analyze all such reports, with the objective to initiate appropriate corrective and preventive action Ensure that all accidents and hazardous occurrences are periodically evaluated and findings are presented to the Management Communicate the analysis of all such incidents to the fleet RECORD AND REFERENCE DOCUMENT NAME DOCUMENT NO. LOCATION APPENDIX NC/CAR FORM FOM 9.1 A Company Forms ACCIDENT/INCIDENT REPORT INCIDENT AS NEAR MISS REPORT AND ANALYSIS LOG EXTRACT FOM 9.1 B FOM 9.1 C FOM 9.1 D Company Forms Company Forms Company Forms