January 22, 1992
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
FROM: PATRICIA K. CLARK, Director
Directorate of Compliance Programs
SUBJECT: Use of Filler Compounds Such as "Bondo" to Cover and
Conceal Structural Damage to Maritime Cargo Handling Gear
It has been brought to our attention that structural damage to cargo
handling gear installed on vessels is being concealed by covering over
damaged areas with a filler material such as "Bondo." Suspect areas where
this condition might exist can be identified by lightly striking the surface
with a hammer which causes the filler material to crack and fall out.
Currently, we are aware of this recognizable unsafe practice having been
identified on the following foreign registry vessels while conducting
longshoring operations in U.S. ports on the west coast: M/V SUN PACIFIC (NKK
Registry), M/V HELM STAR (NKK Registry), and M/V BLUE COSMOS (NKK Registry).
However, compliance officers are to be advised that this practice could occur
on any vessel-mounted or shore-based cargo handling gear. Agencies
accredited to certificate maritime cargo handling devices have been advised
of this unsafe practice by separate correspondence.
Concealing structural damage on cargo handling gear constitutes an extremely
serious and unsafe occupational hazard. If you have any additional
information or documentation with respect to incidents involving this unsafe
practice, please contact [the Division of Maritime Compliance Assistance at