Safety, Quality & Environment Management Manual SQEMM 18-00 Deficiency Management	Doc No.: SQEM-18-00 Revision: 01 Date: 15 Oct 2024 Issued by: DPA Approved by: MD

18.1 PURPOSE

a) The purpose of this procedure is to ensure that the Company shall include established and maintained documented procedures for ensuring that non-conformities, including accidents and hazardous situations, are reported, investigated, and analyzed with the objective of improving safety, quality, pollution prevention and continual improvement of the SQEMS.

18.2 SCOPE

This procedure shall apply to all preventive and corrective actions, which shall be initiated by any incident of non-conformance or non-compliance noticed during audits, inspections, or observed by vessels using policies and objectives; audit results; analysis of data; corrective and preventive action; and management reviews.

18.3 RESPONSIBILITY

a) The President/COO/MD shall have the overall responsibility and authority for handling and investigating non-conformance regarding Company services and vessel operations. He shall further ensure that each GM and DP/MR and operational group is responsible and has the authority for handling and investigating SQEMS non-conformances, for acting to mitigate any impacts caused, and for initiating and completing corrective and preventive action.

18.4 REPORTING & HANDLING OF INCIDENTS (ACCIDENTS AND NON-CONFORMITIES)

a) The Company shall implement a system for reporting all types of non-conformities; accidents, incidents, near misses, dangerous & unwanted situations, which is referred to as the Company Non-Conformity Reporting System, to ensure that all such situations are reported to the Company, authorities, Classification society, Flag States where applicable and other sources, if relevant, per mandatory rules & regulations.

b) All accidents, injuries, hazardous occurrences, damages, Non-Conformities/Observations shall as soon as possible, be reported through the Company’s Reporting System.

c) The Company shall deal with the nonconforming products and services through one or more of the following methods:

• Establish procedures for the incident-investigation process to ensure that the root causes and factors contributing to an incident or accident are clearly identified.
• Taking necessary remedial action regarding the nonconformity to mitigate impacts and eliminate the nonconformity.
• Initiating, implementing, and completing corrective action and preventive action.
• Authorizing its release or acceptance under concession by a relevant authority and, where applicable, the Customer.

d) Systematic reporting and analysis of accidents, incidents, and non-conformities are considered an important way to avoid reoccurrence and to improve the following:

• Safety for the personnel
• Safe ship operation
• Environment protection
• Identifying potential risks and opportunities

e) The system is further elaborated on in the COM 2.4, FOM 10.3 & FOM 10.4.

18.5 CONTROL OF NONCONFORMING MATERIALS, EQUIPMENT OR CARGO SPACES

a) The Company shall establish and maintain documented procedures to ensure that unsuitable materials, equipment, or cargo spaces are identified and prevented from unintended use. Control shall include positive measures to provide for identification, documentation, evaluation, segregation (where practical), and notification of functions concerned.

b) Appropriate corrective action shall be taken for cargo spaces with conditions that do not conform to contractual requirements. Cargo spaces shall not be loaded without prior consent of the Customer. The Customer shall be advised of the condition of the cargo space as a basis upon which to accept the condition with or without concession. Condition and concessions of the cargo spaces shall be recorded, when required.