Subchapter M - USCG Option

Subchapter M - USCG Option October 22, 2013

Annual Inspection • A towing vessel choosing (or required to have) the USCG Option MUST undergo an annual inspection within 3 months – before or after – each anniversary date • Owner/operator contacts the OCMI for date/place • Similar to COI Inspection but may be less detail • COI is endorsed by OCMI after Inspection • Deficiencies in vessel’s maintenance have to be repaired or improved in OCMI’s timeframe • Inspector can conduct tests and inspections as he deems necessary Subchapter M - USCG Option

Periodic Inspection • The vessel must also undergo a periodic inspection within 3 months – before or after – the second or third anniversary date of the vessel’s COI. This takes the place of the annual inspection. • Owner/operator contacts the OCMI for date/place. • No written application is required. • Scope is the same as for a COI Inspection • OCMI endorses COI after Inspection • Deficiencies in vessel’s maintenance have to be repaired or improved in OCMI’s timeframe • Inspector can conduct tests and inspections as he deems necessary Subchapter M - USCG Option

Compliance with the USCG Option • Owner/Operators with more than one towing vessel required to have a COI and choosing the USCG Option, MUST ensure that each vessel under their ownership or control is issued a valid COI according to this schedule: • Within 3 years of the final rule, 25% of the fleet • Within 4 years of the final rule, 50% of the fleet • Within 5 years of the final rule, 75% of the fleet • Within 6 years of the final rule, 100% of the fleet Subchapter M - USCG Option

CERTIFICATE OF INSPECTION A towing MAY NOT be operated without having onboard a valid COI issued by the USCG. Each towing vessel certificated under these provisions MUST be in FULL compliance with the terms of the COI A temporary COI may be issued to prevent delays while waiting for the regular COI. Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • A COI describes the following: • Vessel • Route(s) it may travel • Minimum manning requirements • Minimum safety equipment carried • Horsepower • Other information pertinent to • the vessel’s operations as • determined by the OCMI Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • Obtaining a COI • Make an application to the OCMI of the marine inspection zone in which the towing vessel is principally operated or in which management offices are maintained • Complete form CG-3752 “Application for Inspection of a US vessel” • Provide objective evidence that the vessel’s structure and stability and essential systems comply with applicable requirements of Sub M for intended route and service. This evidence can be an approved third party report. • Provide vessel specific information Subchapter M - USCG Option

CERTIFICATE OF INSPECTION A COI is valid for 5 years from date of issue A COI can be suspended or revoked at any time for non-compliance with the requirements of Sub M The original COI MUST be framed under glass and posted in a conspicuous place on the vessel. Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • The area of operation for each towing vessel and any operational limits is determined by the OCMI and recorded on the COI. The major headings for each area of operation (Route) are: • Oceans • Coastwise • Limited Coastwise • Great Lakes • Lakes, Bays and Sounds • Rivers Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • Further limitations imposed or extensions granted are described by reference to: • Bodies of Water • Geographical Points • Distances from Geographical Points • Distances from Land • Depths of Channel • Seasonal Limitations • Similar Factors as determined by the OCMI Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • Operation of the vessel on a route of lesser severity than those specifically described or designated on the COI is permitted unless expressly prohibited on the COI. The general order of severity of routes is: • Oceans • Coastwise • Limited Coastwise • Lakes, Bays and Sounds • Rivers • Local conditions could cause the OCMI to prohibit operation on a route of lesser severity Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • When designating a permitted route or imposing operational limits on a towing vessel, the OCMI may consider: • The route specific requirements of Sub M • The performance capabilities of the vessel based on: • Design • Scantlings • Stability • Subdivision • Propulsion • Speed • Operating modes • Maneuverability • Other characteristics Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • When designating a permitted route or imposing operational limits on a towing vessel, the OCMI may consider: • The suitability of the vessel for nighttime operations and use in all weather conditions • Vessel operations in globally remote areas or severe environments not covered in this SubChapter. Such areas may include, but are not limited to: • Polar regions • Remote islands • Areas of extreme weather • Other remote areas where timely emergency assistance cannot be anticipated Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • Permit to Proceed • A vessel may need permission to proceed to another port for repairs if it is no longer in compliance with its COI. • The vessel may proceed to another port if: • In the judgment of the Owner/Operator or Master the trip can be completed safely • The owner/operator MUST notify the OCMI in whose zone the non-compliance occurs or is discovered before the vessel proceeds and any other OCMI zones through which the vessel will pass. Subchapter M - USCG Option

CERTIFICATE OF INSPECTION • Permit to Proceed • A vessel may need permission to proceed to another port for repairs if it is no longer in compliance with its COI. • The vessel may proceed to another port if: • The vessel will not engage in towing unless the OCMI deems it safe to do so • The OCMI may require inspection of the vessel by a USCG Marine Inspector or examination by an approved third party prior to the vessel proceeding. Subchapter M - USCG Option

CERTIFICATE OF INSPECTION PERMIT TO CARRY AN EXCURSION PARTY A towing vessel MUST obtain approval to engage in an excursion prior to carrying a greater number of persons than permitted by the COI or a temporary extension or alteration of the area of operation. The vessel may not engage in towing during the excursion unless the OCMI deems it safe to do so. The OCMI may require the inspection of the vessel by a USCG Marine Inspector or examination by an approved third party. Subchapter M - USCG Option

46 CFR PART 137 - VESSEL COMPLIANCE • SURVEYS (TSMS Option but same idea for USCG Option) • A survey of the towing vessel must determine that the item or system • Functions as designed • Is free of defects or modifications that reduce its effectiveness • Is suitable for the service intended • Functions safely in a manner • consistent for the vessel type, • service and route Subchapter M - USCG Option

46 CFR PART 137 - VESSEL COMPLIANCE SURVEYS (TSMS Option but same idea for USCG Option) A Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN No later than three years after the effective date of the final rule, the Owner/Operator MUST implement a health and safety plan. The plan must include record-keeping procedures. Records must document compliance with this part. The Owner/Operator and Master MUST ensure that all persons onboard a towing vessel comply with the health and safety plan. Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN The Owner/Operator MUST implement procedures for reporting unsafe conditions and MUST have records of the activities conducted under this section. Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • According to OSHA, the management system contains four basic elements: • Management Leadership and • Employee Involvement • Worksite Analysis • Hazard Prevention and Control • Training • Each element has sub-elements and all require documentation Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • Management Leadership and Employee Involvement • Worksite Policy • Current year’s goals, objectives, action plans and program evaluation • Job Descriptions that include H & S responsibilities • Performance Evaluations • Budget showing money allocated to H & S • Contractor bidding sheets with their H & S records • Orientation outline for all visitors/contractors • Evidence of employee involvement Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • Worksite Analysis • Results of baseline S & H surveys w/hazard corrections • Forms used to change analyses, inc S & H considerations for purchasing new equipment, chemicals or materials • JHA’s • Employee reports of hazards • Site S & H inspection results w/corrections • Accident investigation reports w/hazard corrections • Trend Analysis results Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • Hazard Prevention and Control • Four step disciplinary system for violation of S & H rules • Use of outside professionals to analyze site for S & H • Employee Medical records • Ability of employee to perform jobs • Job limitations or accommodations needed • Length of time for limitations • Hazard Communication Program • Hearing Conservation Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • Hazard Prevention and Control • Bloodborne Pathogens Program • Confined Space Program • Lockout/Tagout • Emergency Evacuation Program • Required PPE including Respiratory Protection • Preventive Maintenance Schedules • Site Rules Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • Hazard Prevention and Control • Written programs mandated by federal agencies • Maintenance records • Emergency drill procedures and critiques • Health surveillance and monitoring records • Reports and investigations of near misses, first aid and incidents Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • Training • New crew orientation • Weekly safety meetings, training and drills • Maintenance of employee training records • List of yearly training topics with trainer and his qualifications • Yearly training class schedule with attendance lists • Individual training records with evidence of subject mastery. Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • USCG Safety & Environmental Health Manual (336 pages) • Vessel Safety Program Elements - Section 8 • POLICY: Safety is an integral part of all USCG operations. All members must commit to personal responsibility to safeguard themselves, fellow crew members, and the property entrusted to their care. The leadership and responsibility for all safety programs must originate from senior leadership and follow the chain of command to each individual in the command. Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • USCG Safety & Environmental Health Manual (336 pages) • Vessel Safety Program Elements - Section 8 • GOAL: The goal of the Vessel Safety Program is to improve safety, enhance mission effectiveness and increase the operational readiness of all USCG floating units by: • Identifying the loss exposures that endanger our people, platforms, equipment and mission readiness Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • USCG Safety & Environmental Health Manual (336 pages) • Evaluating the associated risks • Controlling our accidental losses Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN • What’s in a Health & Safety Plan? • USCG Safety & Environmental Health Manual (336 pages) • Elements • Scope • Authority • Standards • Organization • Safety & Environmental Health Audits • Training • Pre-Mishap Plan (Emergency Response + SOP’s) Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN Does a Health & Safety Plan Make A Difference? Subchapter M - USCG Option

46 CFR PART 140 – HEALTH & SAFETY PLAN Subchapter M - USCG Option

Subchapter M - USCG Option