Note 16  Contingencies: INSWs policy for recording legal costs related to contingencies is to expense such legal costs as incurred. ? Multi-Employer Plans The Merchant Navy Officers Pension Fund (MNOPF) is a multi-employer defined benefit pension plan covering British crew members that served as officers on board INSWs vessels (as well as vessels of other owners). The trustees of the plan have indicated that, under the terms of the High Court ruling in 2005, which established the liability of past employers to fund the deficit on the Post 1978 section of MNOPF, calls for further contributions may be required if additional actuarial deficits arise or if other employers liable for contributions are not able to pay their share in the future. As the amount of any such assessment cannot currently be reasonably estimated, no reserves have been recorded for this contingency in INSWs condensed consolidated financial statements as of September 30, 2018. The next deficit valuation is due March 31, 2019. The Merchant Navy Ratings Pension Fund (MNRPF) is a multi-employer defined benefit pension plan covering British crew members that served as ratings (seamen) on board INSWs vessels (as well as vessels of other owners) more than 20 years ago. Participating employers include current employers, historic employers that have made voluntary contributions, and historic employers such as INSW that have made no deficit contributions. Calls for contributions may be required if additional actuarial deficits arise or if other employers liable for contributions are unable to pay their share in the future. Based on the latest estimated deficit valuation using a measurement date of March 31, 2017, which was distributed to employers in August 2018, INSW recorded a reserve of 172 ($ 224 ) as of September 30, 2018 for the estimated deficit assessment by the trustees of the MNRPF. The Company made a deficit payment 123 ( $163 ) in October 2018 and expects to pay the balance of the deficit assessment in October 2019. ? Galveston Accident In late September 2017, an industrial accident at a leased facility in Galveston resulted in fatalities to two temporary employees. In accordance with law, an investigation of the accident is currently underway by the Occupational Safety and Health Administration and local law enforcement. In addition, lawsuits relating to the accident, each of which claims damages in excess of $25,000 were filed in state court in Texas (Harris County District Court) and identified a subsidiary of the Company as one of several defendants. The lawsuits have been settled as to most of the original defendants, with the exception of the subsidiary, and the remaining disputes were removed to federal court in Texas (Southern District) in January 2018. The subsidiary has filed its answer to those complaints, generally denying the allegations and stating certain affirmative defenses, and has a pending dispositive motion seeking dismissal of all claims against it. The subsidiary separately filed an action for declaratory judgment in federal court in Texas (Southern District) seeking judgment that it does not owe contractual indemnification obligations to certain of the other original defendants (the T&amp;T Defendants). In July 2018, t he federal court overseeing the declaratory judgment action issued an order dismissing the case on the basis that it lacked subject-matter jurisdiction to hear the dispute. This was not a decision on the merits of the underlying contractual dispute. The subsidiary and its excess insurers, who are co-plaintiffs in the action, have filed an appeal of that decision in the U.S. Fifth Circuit Court of Appeals and are currently awaiting issuance of a briefing schedule . I n the meantime, the T&amp;T defendants filed a new lawsuit in a Texas state court to assert their contractual claims against the subsidiary and its insurers, which the defendants then removed to federal court in Houston, Texas, where it currently is pending with preliminary liability dispositive motions due in early November 2018 . The Company intends to vigorously defend these suits. Estimating an amount or range of possible losses resulting from litigation proceedings is inherently difficult and requires an extensive degree of judgment, particularly where the matters involve indeterminate claims for monetary damages and are in the stages of the proceedings where key factual and legal issues have not been resolved. Accordingly, the Company is currently unable to predict the ultimate timing or outcome of, or to reasonably estimate the possible loss or a range of possible loss resulting from, these matters. ? Legal Proceedings Arising in the Ordinary Course of Business The Company is a party, as plaintiff or defendant, to various suits in the ordinary course of business for monetary relief arising principally from personal injuries, wrongful death, collision or other casualty and to claims arising under charter parties and other contract disputes. A substantial majority of such personal injury, wrongful death, collision or other casualty claims against the Company are covered by insurance (subject to deductibles not material in amount). Each of the claims involves an amount which, in the opinion of management, should not be material to the Companys financial position, results of operations and cash flows. ?