U.S. Coast GuardU.S. Coast GuardNotice of Proposed RulemakingNotice of Proposed Rulemaking
Inspection of Towing VesselsInspection of Towing Vessels
Articulated tug-barge
Sept 20111
Inspection of Towing VesselsInspection 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 2
Inspection of Towing VesselsInspection 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.
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Ocean-going Tugboat
Inspection of Towing VesselsInspection 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.
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Inspection of Towing VesselsInspection of Towing Vessels
• Regulation sought by the American Waterways Operators (AWO).
• Creates single agency (Coast Guard (USCG)) oversight.
• Levels the playing field across the industry by establishing base standards.
• Therefore, the USCG established a joint working group with the AWO to improve safety.
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Inspection of Towing VesselsInspection 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 Towboat6
Inspection of Towing VesselsInspection 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.
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Operations in fleeting area
Inspection of Towing VesselsInspection 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 8
Inspection of Towing VesselsInspection 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
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Line Haul
Inspection of Towing VesselsInspection 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.
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Towboat pushing two covered hoppers, likely carrying grain, and one tank barge.
Inspection of Towing VesselsInspection 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.
• TSMS + audits, surveys, andCG oversight = a dynamic system. 11
View from the pilothouse
Inspection of Towing VesselsInspection 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
12
Inspection of Towing VesselsInspection 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
13
Inspection of Towing VesselsInspection 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
14
Inspection of Towing VesselsInspection 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
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Inspection of Towing VesselsInspection 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.16
Inspection of Towing VesselsInspection 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
Complianc
e
17
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A Bridge to Inspection…A Bridge to Inspection…
04/21/23
Mr. Patrick LeeTowing Vessel National Program CoordinatorOffice of Vessel Activities (CG-5431)202-372-1135
19
Towing Vessel Bridging Program
Why do we need a bridge?
04/21/23
04/21/23 20
A Phased Approach…
Phase 1Outreach & EducationIIEsTesting of Risk ToolQualification/PQSId of FORs
Phase 2Prioritized ExamsCourse DevelopmentComments on NPRM100% FORs examined
Phase 3COI IssuanceFormal Training
Summer 2009Subchapter “M”
Published
Law Enforcement Boardings & Surge Operations
Enclosure (1)
Phase 2 Prioritization Matrix
04/21/23
22 04/21/23
UTV Fleet of Responsibility
What is it? Who is it? What can it do for me?
04/21/23 24
United States Coast GuardTowing Vessel National Center of Expertise
04/21/23 25
Towing Vessel National Center of Expertise
United States Coast GuardTowing Vessel National Center of Expertise
Why is the Center of Expertise in Paducah?
Hub of the inland waterways
Tow Boat City USA
Seamen’s Church Institute
04/21/23 26
United States Coast GuardTowing Vessel National Center of Expertise
The TVNCOE Team
Active Military:
LCDR Russell LCDR Bethke LCDR KeoghSupervisor Asst. Supervisor InspectorCOE Manager Asst. Manager InvestigatorInspector InspectorCivilians:
Roy Murphy Steven Douglass Bill Perkins Mike Kelly Industry Industry USCG retiredUSCG retiredLicensed Master Licensed Master Inspector Inspector Training Chief Engineer InvestigatorInvestigator
United States Coast GuardTowing Vessel National Center of Expertise
04/21/23 28
United States Coast GuardTowing Vessel National Center of Expertise
CG’s Experts on Towing Vessels
TrainingAssist in the development of curriculumImprove consistency of exams, inspections
Information brokersGather, organize, distribute important data
Subject Matter ExpertiseIdentify issues and help shape policyBring the industry and Coast Guard together
04/21/23 29
United States Coast GuardTowing Vessel National Center of Expertise
Training UTV Examiner Course
Total = 8 (FY10 & FY 11)CG Students trained = 152Industry reps participated = 52Companies represented = 33
Other OutreachFirefighting Pressure vessel
04/21/23 30
United States Coast GuardTowing Vessel National Center of Expertise
TVNCOE Website
Quick access to towing vessel information
Centralized location for current CG policies, guidebooks, PQS manual, job aids, etc
Links to other resources
News & Eventswww.uscg.mil/tvncoe
04/21/23 31
United States Coast GuardTowing Vessel National Center of Expertise
04/21/23 32
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