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Towing Vessel Bridging Program Mr. Mike White Towing Vessel Branch Coast Guard District Eight. Towing Vessel Bridging Program. Why do we need a bridge?. A Phased Approach…. Phase 3 COI Issuance Formal Training. Phase 2 Prioritized Exams Course Development Comments on NPRM
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Towing Vessel Bridging Program Mr. Mike White Towing Vessel Branch Coast Guard District Eight
Towing Vessel Bridging Program Why do we need a bridge?
A Phased Approach… • Phase 3 • COI Issuance • Formal Training • Phase 2 • Prioritized Exams • Course Development • Comments on NPRM • 100% FORsexamined • Phase 1 • Outreach & Education • IIEs • Testing of Risk Tool • Qualification/PQS • Id of FORs Subchapter “M” Published Summer 2009 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)
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 117 313 225 415 3955 343 158 347 66
D8 FOR Breakdown • Sector Houston 499 • Sector Corpus 83 • Sector New Orleans 1563 • Sector Mobile 224 • Sector Lower 237 • Sector Upper 416 • Sector Ohio Valley 933 D8 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-bargeAug 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 Vessels 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. 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 Vessels 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. 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 to towing 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 Vessels Compliance Phase-in for a Towing Company Final Rule YR 0 YR 2 YR 6 YR 11 TSMS 2yrs fm FR Compliance COI 4yrs fm TSMS 25% p/yr Deferred Machinery & Electrical (M&E) 5yrs fm COI Deferred redundancy M&E 5yrs from COI