Towing Vessel Bridging Program

Mr. Mike White

Towing Vessel Branch

Coast Guard District Eight

Towing Vessel Bridging ProgramWhy do we

need a bridge?

A Phased Approach…

Phase 1 Outreach & Education IIEs Testing of Risk Tool Qualification/PQS Id of FORs

Phase 2 Prioritized Exams Course Development Comments on NPRM 100% FORs examined

Phase 3 COI Issuance Formal Training

Summer 2009Subchapter “M”

Published

Law Enforcement Boarding's & Surge Operations

Phase I results…• New UTV examiners are qualified/knowledgeable

and have built industry partnerships• TVNCOE stood up and running course/portal• Industry Initiated Exams YTD– 2520• Def Checks YTD – 1388• Decals Issued YTD – 2089 – Decal is not the goal• Industry and CG consider TVBP a success

(positive press/flag letters/outreach/peer pressure)

Phase 2 Prioritization Matrix

•Company has not participated in Phase 1

•Vessel has not been examined

High Priority Vessel

•Company participating in Phase 1•Vessel has not been examinedLow Priority

Vessel

•Company participating in Phase 1•Vessel has been examinedNon-Priority

Vessel

D8 efforts thus far…

• D8 Fleet of Responsibility 3955 vessels• 134 UTV Examiners in D8• Participating in all SIX (6) WGs, TSAC,

OMSA, and AWO meetings

UTV Fleet of Responsibility

415

343347

3955158

313

66

117

225

D8 FOR Breakdown• Sector Houston 499• Sector Corpus 83• Sector New Orleans1563• Sector Mobile 224• Sector Lower 237• Sector Upper 416• Sector Ohio Valley 933D8 Total = 3955

Common Deficiencies

• Fire Detection• Fuel Shut Offs • Fire Pumps• B-V Semi Portable Fire Extinguisher• General Alarm issues, Blue Light, Signage• Fixed Piping (Oil Discharge)

U.S. Coast GuardNotice of Proposed Rulemaking

Inspection of Towing Vessels

Articulated tug-barge

Aug 11, 2011

Inspection of Towing Vessels

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

Inspection of Towing VesselsCurrent 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.

Ocean-going Tugboat

Inspection of Towing Vessels

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.

Inspection of Towing Vessels

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 Towboat

Inspection of Towing VesselsNotice 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.

Operations in fleeting area

Inspection of Towing Vessels

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

Inspection of Towing Vessels• 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

Line Haul

Inspection of Towing Vessels

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.

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

Inspection of Towing Vessels

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.

View from the pilothouse

Inspection of Towing Vessels

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

Inspection of Towing Vessels

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

Inspection of Towing Vessels

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

Inspection of Towing Vessels

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

Inspection of Towing Vessels

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.

Inspection 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

Compliance

Questions?