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resulted when the crew tried to test heat detectors with an nex I de?ciencies. In most cases, the de?ciencies were re- open ?ame or heat gun. lated to the oily water separators not being able to produce

Overall, detainable de?ciencies related to lifesaving sys- an ef?uent below 15ppm. However, during one exam, the tems have remained steady over the last three years account- PSC team discovered unapproved modi?cations to the oily ing for less than 10% of the total. De?ciencies related to water separator piping system. Speci?cally, a ball valve was rescue boats and lifeboats lead the category this year, mostly installed to bypass the oil content meter photo eye. This al- due to not being ready for immediate use. In some cases, lowed ef?uent greater than 15ppm to be discharged directly the engines could not be started and in others, there were overboard. If PSCOs discover cases of bypassed OWS equip- problems related to the davits and falls. For 2019, the Coast ment or instances of falsi?ed oil record books, criminal pros-

Guard recorded two detainable de?ciencies related to per- ecution of the vessel and its crew by the U.S. Department of sonal lifesaving equipment. One was for a ship having only Justice may result.

14 lifejackets on board for a crew of 21 and the other was

LAG DMINISTRATION AFETY AND ECURITY ERFORMANCE when the PSCO discovered zippers separated from over half F A S S P of the ships immersion suits. Flag administration safety performance for 2019 re-

MARPOL Annex I de?ciencies increased over last year’s mained steady with the overall annual detention rate slightly totals. Yet, for 2019, only 9% of detainable de?ciencies were decreasing from 1.14% to 1.12%. However, the three-year

MARPOL Annex I related. De?ciencies related to oil ?l- rolling detention ratio increased slightly from 1.06% to tering equipment accounted for over 30% of the total An- 1.08%. The ?ag administrations of Cyprus, India, and Tur- key were removed from the Coast Guard’s Targeted Flag List for 2019. Flag administration security performance for 2019 increased slightly resulting in the annual Control Action Ra- tio (CAR) decreasing from 0.09% to 0.08%. The three-year rolling average CAR held steady at 0.08%. Additionally, for the fourth straight year, there were no ?ag administrations listed on our ISPS/MTSA targeted matrix.

D A AETENTION AND SSOCIATION PPEALS

In 2019, the Coast Guard received a total of 39 appeals.

Twenty-three appeals were submitted challenging the overall merits of the detention. For those merit appeals that have been ?nalized, six were granted and 10 were denied. There are currently seven merit appeals still under consideration.

In addition to receiving appeals contesting the overall merits of a detention, the Coast Guard also received 16 ap- peals requesting the removal of a party’s association with a detention. Of those 16, six were denied and eight were granted. Two are still under consideration.

QUALSHIP 21 E-Z PAND ERO ROGRAMS

The QUALSHIP 21 (QS21) program ended calendar year 2019 with 2,936 vessels enrolled. In 2018, nine additional ?ag administrations were welcomed into the program with only one losing its QS21 eligibility. For 2019, despite the decrease in total detentions, four ?ag administrations lost their eligibility while two additional ?ags became eligible.

The E-Zero program focuses on environmental steward- ship and worldwide compliance with international environ- mental conventions. By the end of 2019, 51 ships received the E-Zero designation.

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