Towing Vessel Inspection - Brownwaterbrownwateruniversity.org/8_Towing Vessel Inspection.pdf · Towing Vessel Inspection 9/10/2013 . ... the RCP Auditor Accreditation and Training

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9/10/2013

Towing Vessel Inspection

I n l a n d R i v e r s a n d G u l f C o a s t – 2 0 1 3

Section 8 Towing Vessel Inspection

Navigation Safety Panel Discussion

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9/10/2013

Moderator Tava Foret

Coast Guard Perspective LT Edward Ayoub MST1 Bryan Vitrano

Industry Perspective Tava Foret Tom McWhorter


L T A Y O U B - U N I N S P E C T E D V E S S E L S D I V I S I O N , M S U P O R T A R T H U R

M S T 1 V I T R A N O , U N I N S P E C T E D V E S S E L S D I V I S I O N , S E C T O R H O U S T O N - G A L V E S T O N

Coast Guard Perspective 3

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The Good


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The Bad

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The Ugly

0300 September 23,

1993

47 DEAD

Caused by Towing Vessel’s Pilot becoming disoriented in heavy fog and striking bridge. Deadliest accident in Amtrak’s history – Big Bayou Canot Bridge, Mobile, AL

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American Waterway Operators

1994 – Established its own voluntary “Responsible Carrier Program” Operations incl. fuel transfer procedures

Safety Training

Environmental policy

Incident Reporting

Emergency Response and Equipment

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American Waterway Operators

1998 – Made “Responsible Carrier Program” mandatory for its members. Must undergo 3rd party audits

By 2000 all members had been audited (10% every 3 years)

13 companies left the organization rather than face the audit.

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Maritime Transportation Act of 2004

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Summer 2009 Phase 1 Began

108 Dedicated Billets – New UTV Examiners are qualified/knowledgeable and build industry partnerships.

Establishment of an NCOE

Funding for Training

Industry Initiated Exams (IIE)

Decal Issuance

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A Phased Approach…

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

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

Phase 3 COI Issuance Formal Training

Summer 2009

Subchapter “M” Published 01JUL12


Phase II

• Began 01JUL12

• Phase II wasn’t supposed to start until ALL Districts were ready

• Port State Information eXchange (PSIX) was supposed to be enabled

• Industry Initiated Exams to continue in Phase II and to take priority

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Targeting Matrix

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66%

20%

14%

Decaled Issued

Decal Not Issued

Unexamined*

*0 vessels in operation

left to be examined.

MSU Port Arthur Approx. 65 UTVs


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Future of MSU PA UTVs

Continue Phase II efforts

Ramification of SIRE Inspections Decal Renewals

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Total FOR = 509

Sector H/G = 329

MSU Texas City = 36

MSU Port Arthur = 65

MSU Lake Charles = 79

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Compliance Issues

After more than 6300 uninspected towing vessel exams, some key issues have surfaced.

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Current Compliance Issues

• Fuel Shut-Off Valves required by 46 CFR 27.203

• Location

• Marking

• Operation

• General Alarms required by 46 CFR 27.201

• Marking

• Supplemental flashing red light

• Navigation Lights required by 46 CFR 25.10-3

• Technical standards

• Approved type

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• Drug & Alcohol Testing/Records - 46 CFR 4.06 & 16

• Testing devices - expiration date/improper stowage

• Record keeping - random testing

• EAP Program - display and distribution of training materials

• Recordkeeping – 47 CFR 80 & 33 CFR 164.80

• Radiotelephone logs maintenance and entries

• Record of test and inspections before getting underway

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• Magnetic Compass/Swing Meter - 33 CFR 164.72 • Not fitted or functioning

• Wrong equipment for area of operation

• Not properly illuminated

• Fire Detection Equipment - 46 CFR 27.203 • Panel inoperable

• Panel not properly labeled

• Proof of PE certification

• Marine Sanitation Devices - 33 CFR 159.7 • Not properly labeled

• Not properly secured against overboard discharge

• Inadequate supplies for proper operation

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• Vessel Markings - 46 CFR 67.121

• Official Number not in accordance with requirements • Official Number not permanently fixed

• Fire Extinguisher Brackets - 46 CFR 162.028-3

• Not approved type

• Pressure Vessels *******

• Missing data plates • Improper PV valves • Nonstandard • Improper repairs

• Note: Not currently regulated on UTV’s but my be classified as a Hazardous Condition

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Towing Vessel National Center of Expertise

TOWING VESSEL NATIONAL CENTER OF EXPERTISE

OFFICE: (270) 444-7715 (X-203)

FAX: (270) 444-8094

Web Address – WWW.USCG.MIL/TNVCOE

http://www.uscg.mil/TNVCOE

Industry Perspective 25

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Towing Vessel Inspection Bureau

What one segment of the Towing Vessel industry is doing to prepare for Towing Vessel Inspections under 46 CFR Subchapter M

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The Future of Auditing

Following the evolution of the TSAC Subchapter M process that began in 2004 that included: the review of 2 sets of draft language,

the publishing of the NPRM in August of 2011,

and the public hearings,

It appeared there was an area of Subchapter M that needed more attention

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More Work To Be Done

There were several issues to consider: Would there be enough qualified auditors for Sub M?

How would they be trained?

What would happen if there were 20 different accepted organizations, each using different methods for conducting audits and each and submitting different audit reports?

Could the Industry and Coast Guard reasonably expect consistency in auditing?

With inevitable inconsistency could there be long-term acceptance of Sub M?

What would be the fallout?

Who would suffer most from any push back?

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A Solution

Formation of TVIB as a Professional Trade Organization for Marine Auditors and Surveyors to: Review credentials, experience and work history

Develop a common audit tool for management and vessel audits

Provide Training on the Regulatory Standard

Set Member Standards and Guidelines

Advocate on behalf of the Auditor Member

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What Is TVIB?

Non-profit organization formed in 2010

Filed for 501(c)(6) in 2013

Two Member Categories: Auditor Membership

Supporting Organization Membership

Member-owned and governed

Organization was turned over to the membership in May of 2013 and is now governed by the 21-member Board of Directors and an Executive Director

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Purpose, Goals and Objectives

Train and certify members to conduct audits and inspections

Perform the training and accreditation function for the American Waterways Operators Responsible Carrier Program (RCP).

Pending the Final Rule – Conduct training and accreditation function for auditors/surveyors working for USCG accepted organizations providing third-party audits and/or surveys under Subchapter M

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The AWO Responsible Carrier Program®

Early Fall of 1993 – External and Internal Factors

April 1994 – Development of the RCP

April 1998

January 1, 2001 – 100% of the AWO Carrier Members were in compliance

SIDE NOTE – 2004 Subchapter M began

2008 – the board voted to get out of the auditor accreditation business and later reaffirmed that decision

2013 - TVIB entered into a 10-year agreement to assume the RCP Auditor Accreditation and Training Function from AWO

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AWO-TVIB Agreement Overview

TVIB will provide the following in connection with the RCP:

Certification of Auditors

Conduct initial and recertification training

Address auditor questions concerning the RCP

TVIB will not directly oversee auditor’s performance of audits

Provide Continuing Education to the Auditors

Develop and administer procedures for appeals and grievances

Develop and enforce a substantive Code of Ethics

Utilize an internal quality system based on an ANSI/Amer. Society of Quality Control Q9001-2000 or equivalent and attain ISO certification

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AWO and TVIB – Today and Tomorrow

Enhanced Management Checklist and Worksheet

TVIB-Certified AWO RCP Auditor Course COMPLETED - August 6-8, 2013 - Houston, TX

November 5-7, 2013 - Nashville, TN

March 2014 – Location TBN

TVIB Upcoming Meetings November 2013 – Board Meeting - Nashville, TN

March 2014 – Annual Members Meeting/Board Meeting – Location TBN

Enhanced Vessel Checklist(s) and Worksheet(s)

3-day Internal Auditor Course

Evaluate the Development of an Electronic Audit Tool

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Committee Structure

Auditor Accreditation and Oversight

Committee

Auditor Resources

Committee

Auditor Certification

•Verifies Credentials

•Evaluates Qualifications

•Issues Final TVIB Credential

Auditor Training

•Prepares and conducts Initial and

refresher training

Auditor Oversight and Quality

Control

•Evaluates Auditors

•Addresses Auditor Complaints

Audit Process

•Develop and continuously improve

the audit process

Audit Checklist

•Develop and continuously improve

the audit checklist/tool

Continuing Education

•Keep Auditor Pool up to date on

changes to the audit process and

audit checklist

•Provide other continuing education

opportunities to the Auditors

Subcommittees

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www.thetvib.org

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Navigation Safety Panel Discussion

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9/10/2013

Moderator Tava Foret

Coast Guard Perspective LT Edward Ayoub MST1 Bryan Vitrano

Industry Perspective Tava Foret Tom McWhorter

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9/10/2013


Coming up next: Western Rivers

Section 8

Documents

Towing Vessel Inspection - Brownwaterbrownwateruniversity.org/8_Towing Vessel Inspection.pdf · Towing Vessel Inspection 9/10/2013 . ... the RCP Auditor Accreditation and Training