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Towing vessel NATIONAL Center of Expertise

Towing vessel NATIONAL Center of Expertise. Towing Vessel National Center of Expertise. STAFF. Active Duty CDR Pat Nelson LCDR Jaime Salinas LT Paris Stratton Civilian Roy Murphy Mike Kelly Steven Douglass Dave Phillips. Vision

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Towing vessel NATIONAL Center of Expertise

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  1. Towing vessel NATIONAL Center of Expertise Towing Vessel National Center of Expertise

  2. Towing Vessel National Center of Expertise Towing Vessel National Center of Expertise

  3. Towing Vessel National Center of Expertise

  4. STAFF Active Duty CDR Pat Nelson LCDR Jaime Salinas LT Paris Stratton Civilian Roy Murphy Mike Kelly Steven Douglass Dave Phillips Towing Vessel National Center of Expertise

  5. Vision Be the Coast Guard's forward thinking component in the towing industry to keep all TVBP stakeholders well-prepared to handle current and future needs Mission  • Serve as in-house consultants • Provide technical advice to both industry and the Coast Guard • Increase and maintain the Coast Guard’s collective competency Towing Vessel National Center of Expertise

  6. Professional Objectives Towing Vessel National Center of Expertise

  7. TVNCOE NEW www.uscg.mil/tvncoe

  8. Program elements & expectations Towing vessel bridging program Towing Vessel National Center of Expertise

  9. Purpose Bridge the gap – Ease the transition Towing Vessel National Center of Expertise

  10. Goals Towing Vessel National Center of Expertise

  11. 3 Phases Law Enforcement Boardings & Surge Operations Towing Vessel National Center of Expertise

  12. UTV Fleet of Responsibility = 5571Industry Initiated Exams = 5908Prioritized Exams Remaining = 407 100 89 27 239 329 34 286 257 87 402 345 39 3733 3999 144 164 184 20 287 317 15 295 314 41 65 74 0

  13. Timeline COI 03/15 Final Rule (?) 2011 NPRM 2004 CG Auth Act Implementation 2009 TVBP Steamboat inspections 1800’s Towing Vessel National Center of Expertise

  14. Compliance Phase-in YR 2 YR 8 YR 9 YR 10 YR 0 YR 3 YR 4 YR 5 YR 6 YR 11 Towing Vessel National Center of Expertise

  15. Problems & Solutions Policies & guidance Towing Vessel National Center of Expertise

  16. Lesson Objectives • DETERMINE current policies and guidance • STATEthe Exemptions, Appeals and Equivalencies procedures. • STATE sources to obtain current policies and guidance. Towing Vessel National Center of Expertise

  17. Frequently Asked Questions PORTABLE FIRE EXTINGUISHER INSPECTION/MAINTAINANCE Q. Where can I find information on maintenance and inspections required for portable fire extinguishers? Ans. National Fire Protection Association (NFPA) 10 Standard for Portable Fire Extinguishers. You may obtain a copy of NFPA 10 through the National Fire Protection Association. TVNCOE Towing Vessel National Center of Expertise

  18. Fixed CO2 Systems Issue Policy Letter 10-06 Allows designation of “Excess Equipment” for certain circumstances. • Some systems are not installed IAW 46 CFR 76.15 • Examples: • Bottles over 300lbs capacity located inside space being protected • Inadequate amount of CO2 for space Towing Vessel National Center of Expertise

  19. TVNCOE NEW www.uscg.mil/tvncoe

  20. Awareness Exemptions, appeals & equivalencies Towing Vessel National Center of Expertise

  21. Flexibility in the Law Towing Vessel National Center of Expertise

  22. Equivalencies • 46 CFR 24.15-1 • Granted by COMDT • Substitution that is at least as effective as that specified in regulation. • Examples of equivalencies granted so far: • Fuel shut off valves • NICET Level IV Technicians Towing Vessel National Center of Expertise

  23. Exemption • Only for a specific regulation • Most can be granted by COTP • If denied, owner/operator has right to appeal • Examples: • EPIRB - 46 CFR 25.26-60(b) Dist Cmdr exemption • Fire Protection - 46 CFR 27.100(b)(4) & 27.100(c) • Navigation Safety - 33 CFR 164.01-(b)(4) Towing Vessel National Center of Expertise

  24. Appeals • References • 46 CFR 24.01-7 (will direct the reader to 1.03) • 46 CFR 1.03 • 46 CFR 1.01 • 30-day time limit • Written request • Description of decision/action & why it should be revised Towing Vessel National Center of Expertise

  25. Rules of Thumb for Equivalents, Exemptions, and Appeals • Formal written requests from owner/operators • Must provide justification for request • Submitted thru Chain of Command (via cognizant OCMI/COTP) • COMDT is the highest and final authority on decisions/actions • See process guide at TVNCOE website for help (template letters/memos available) TVNCOE Towing Vessel National Center of Expertise

  26. Questions? Towing Vessel National Center of Expertise

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