U.S. Coast Guard Notice of Proposed Rulemaking Inspection of Towing Vessels Articulated tug-barge...

U.S. Coast GuardU.S. Coast GuardNotice of Proposed RulemakingNotice of Proposed Rulemaking

Inspection of Towing VesselsInspection of Towing Vessels

Articulated tug-barge

Sept 20111


Reason for Proposed Rule

The CG & Maritime Transportation Act of 2004:

• Added towing vessels as a class of inspected vessels.

• Authorized the establishment of a safety management system for towing vessels.

• Authorized the USCG to prescribe maximum hours of service for individuals on towing vessels at least 26 feet in length.

Line-Haul Towboat 2


Current Regulatory Status:

Towing vessels are regulated but most are not inspected.

• The USCG does not issue Certificates of Inspection (COI) to towing vessels unless they are over 300 GT and in oceans service.

• Certain tow vessel components/operationsare only subject to USCG regulations that are:

• Specific to towing vessels

• Applicable to all uninspected vessels

• Applicable to all vessels

• The USCG may board towing vessels for safetyand security checks at any time.

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Ocean-going Tugboat


Historical Background of the Rule

• Dec 2004:

• The USCG published a notice with request for

comments, as well as a notice of public meetings.

• Four public meetings were held.

• American Bureau of Shipping Group (ABSG) Report:• 1-year contractor-supported study:

• Categorized the industry• Analyzed casualty data• Provided economic data

• The USCG visited companies and vessels and internally reviewed accident histories.

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• Regulation sought by the American Waterways Operators (AWO).

• Creates single agency (Coast Guard (USCG)) oversight.

• Levels the playing field across the industry by establishing base standards.

• Therefore, the USCG established a joint working group with the AWO to improve safety.

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http://upload.wikimedia.org/wikipedia/commons/0/08/Img_3381.jpg


Building the Rule

• TSAC involvement:

• TSAC/USCG began working together in the fall of 2004.

• Interactive project.

• Nearly 200 industry representatives

participated.

• Added time to the project but produced

dividends at the end.

• Incorporated TSAC recommendations

into the rule.

Line-Haul Towboat6


Notice of Proposed Rulemaking

• Adds new subchapter (M) to 46 CFR.

• Establishes baseline regulations forinspected towing vessels.

• Defines the Towing Safety ManagementSystem (TSMS) .

• Prescribes qualifications for third-party auditors and related procedures.

• Prescribes procedures for vessel compliance and obtaining a certificate of inspection (COI).

• Reflects cooperation with TSAC.

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Operations in fleeting area


Key Elements

Standards (lifesaving, fire protection, machinery, etc.):• Developed specifically for towing vessels.

Applicability:• Limited to “traditional” towing vessels—for now.• Focused on risk.

Safety Management System: • The core of operations and compliance.• Addresses the human element.• Ties management to vessels.• Used throughout manufacturing, financing, transportation (ISM mandated, RCP proprietary).• Facilitates audited compliance activities.

Third-party auditors and surveyors: • Allows for flexibility—service when/where needed.• Allows the CG to focus on the areas of greatest risk.

Coast Guard Option 8


• 46 CFR subchapter M:• Part 136—CERTIFICATION• Part 137–VESSEL COMPLIANCE• Part 138—TOWING SAFETY

MANAGEMENT SYSTEMS (TSMS)• Part 139—THIRD-PARTY

ORGANIZATIONS• Part 140—OPERATIONS• Part 141—LIFESAVING• Part 142—FIRE PROTECTION• Part 143—MACHINERY AND

ELECTRICAL SYSTEMS AND EQUIPMENT

• PART 144—CONSTRUCTION AND ARRANGEMENT

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Line Haul


Applicability

• In general, this regulation would apply totowing vessels ≥ 26 ft., as well as any towing vessels pushing, pulling, or hauling a barge carrying dangerous or hazardous materials.

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Towboat pushing two covered hoppers, likely carrying grain, and one tank barge.


Towing Safety Management System

• Risk-based: Analysis of accident data and experts’ inputs.

• Human factors: training, safety drills, crew endurance management program, restrictions on hours of service.

• Equipment: lifesaving, fire protection, electrical and machinery,vessel operational requirements.

• Recordkeeping.

• TSMS + audits, surveys, andCG oversight = a dynamic system. 11

View from the pilothouse


Proposed Third Party Concept

The USCG approves third-party auditors and surveyors.+

Companies implement TSMS and ensure vessels meet standards.+

Third parties verify compliance(Audit TSMS / Survey vessels).

+The USCG boards vessels

(Initial / 5yrs / Risk).

+The USCG reviews reports.

=Certificate of Inspection issued to vessels in compliance. Workboat Harbor Tugboat

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Towing Company Responsibilities

• Develop and implement TSMS on vessels and shore side operations.

• Operate under TSMS.

• Maintain vessels in compliance with regulations and TSMS.

Tugboat backing bow around

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Third Party – Auditor and Surveyor Responsibilities

• Review TSMS and approve TSMS if it complies with the proposed requirements.

• Audit TSMS and vessels.

• Survey towing vessels.

Articulated tug-barge in open waters

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Coast Guard Responsibilities

• Approve and oversee third-party auditors and surveyors.

• Ensure CG inspection of every towing vessel at least once every 5 years.

• Additional risk-based boarding of towing vessels.

• Issue Certificate of Inspection (COI).

Tow transiting lock

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Affected Vessels

• 5,208 Towing Vessels (including towboats and tugboats).• Vessels operating in inland rivers, Great Lakes, coasts, and

oceans.• Perform line-haul, fleeting, and harbor assist operations.

Affected Companies

• 1,059 owner/operator companies.• 327 companies, with either a full safety management system or

similar program, control 2,941 vessels.• 827 companies, without safety management systems or similar

programs, control 2,267 vessels.16

Inspection of Towing VesselsInspection of Towing VesselsCompliance Phase-in for a

Towing Company

Final Rule

TSMS2yrs fm FR

YR11

YR0

YR6

YR2

COI4yrs fm TSMS25% p/yr

Deferred Machinery & Electrical (M&E)5yrs fm COI

Deferred redundancy M&E5yrs from COI

Complianc

e

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A Bridge to Inspection…A Bridge to Inspection…

04/21/23

Mr. Patrick LeeTowing Vessel National Program CoordinatorOffice of Vessel Activities (CG-5431)202-372-1135

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Towing Vessel Bridging Program

Why do we need a bridge?

04/21/23

http://www.flickr.com/photos/laughingsquid/1519104482/

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A Phased Approach…

Phase 1Outreach & EducationIIEsTesting of Risk ToolQualification/PQSId of FORs

Phase 2Prioritized ExamsCourse DevelopmentComments on NPRM100% FORs examined

Phase 3COI IssuanceFormal Training

Summer 2009Subchapter “M”

Published

Law Enforcement Boardings & Surge Operations

Enclosure (1)

Phase 2 Prioritization Matrix

04/21/23

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UTV Fleet of Responsibility

What is it? Who is it? What can it do for me?

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United States Coast GuardTowing Vessel National Center of Expertise

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Towing Vessel National Center of Expertise


Why is the Center of Expertise in Paducah?

Hub of the inland waterways

Tow Boat City USA

Seamen’s Church Institute

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The TVNCOE Team

Active Military:

LCDR Russell LCDR Bethke LCDR KeoghSupervisor Asst. Supervisor InspectorCOE Manager Asst. Manager InvestigatorInspector InspectorCivilians:

Roy Murphy Steven Douglass Bill Perkins Mike Kelly Industry Industry USCG retiredUSCG retiredLicensed Master Licensed Master Inspector Inspector Training Chief Engineer InvestigatorInvestigator


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CG’s Experts on Towing Vessels

TrainingAssist in the development of curriculumImprove consistency of exams, inspections

Information brokersGather, organize, distribute important data

Subject Matter ExpertiseIdentify issues and help shape policyBring the industry and Coast Guard together

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Training UTV Examiner Course

Total = 8 (FY10 & FY 11)CG Students trained = 152Industry reps participated = 52Companies represented = 33

Other OutreachFirefighting Pressure vessel

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TVNCOE Website

Quick access to towing vessel information

Centralized location for current CG policies, guidebooks, PQS manual, job aids, etc

Links to other resources

News & Eventswww.uscg.mil/tvncoe

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U.S. Coast Guard Notice of Proposed Rulemaking Inspection of Towing Vessels Articulated tug-barge...

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