Sub M - Implementation 1

Sub M - Implementation Compliance Timeline Highlights of What Changed from NPRM Compliance Options

UTV Fleet of Responsibility 5,719 91 292 230 421 3,905 270 163 Adding nearly 6,000 inspected vessels to the CG inspected fleet…to put that into perspective, we currently have around 12,000 inspected vessels in the U.S. That’s ~7,k pax, 4k barges, 1k OSVs…so you’ll be the second largest fleet inspected by the CG. D8 has 2/3rds of the soon to be inspected towing vessels…so we are the epicenter for this effort. 282 65

Compliance Timeline Deferred Equipment   YR 0 YR 1 & 2 YR 3 YR 4 YR 5 YR 6 YR 7 - 10 YR11 Deferred Equipment Pilothouse alerter system Towing machinery (i.e. winches, bitts, guards etc.) Health and Safety Plan After First Year 22 July 2019 Two year’s before vessels must comply with the requirements…first COIs will not be issued until 20 Jul 2018. That gives (1) CG time to develop/publish policy and train our workforce; and (2) industry time to come into compliance. Provides phase-in period…spreads the workload for CG out over 4 year period. Industry must plan on how they spread their initial CG inspections out over the 4-yr period. New vs Existing – Vessels constructed before 20 Jul 2017 are existing…those after are new vessels and must comply with all requirements that apply to new vessels in Sub M. This is the only exception for vessels that could receive a COI ahead of Jul 2018. 30-day Effective Date TPO requirements TPO approvals Stability, watertight, & weather-tight 20 July 2016 Comply with Sub M - 20July 2018 TSMS Certificate issued by approved TPO 6 months prior to COI Issue: starting 20 Feb 2018 Keel Laid Date New Vessel 20 Jul 2017

Sub M – What Changed from the NPRM See Table 4 in final rule that summarizes the changes. Requirement to minimize distractions – (cell phones, laptops, etc.) User Fee – default $1,030 Objective Evidence for Stability & Drydock to receive initial COI Require owners or operators to maintain watertight integrity & stability. Letter of designation for PIC of fuel transfer – not applicable to inspected vessels. Removed: Remote Engine Shutdown requirement Automatic external defibrillators and train crewmembers in their use. New Electrical system requirements for existing towing vessels Clarified requirements for independent means of propulsion, steering and related controls on towing vessels moving tank barges – applies to new vessels only

Sub M – Compliance Options Options for certification of a towing vessel: Coast Guard Option TSMS Option: External Survey Program Internal Survey Program ISM option – Recognized Classification Society (External/Internal)

Coast Guard Will: Towing Company Will: Issue COIs – set routes & manning Perform annual inspection Attend drydock & internal structural exams Issue deficiencies Oversee Repairs Conduct Drills New Construction/Major modifications oversight Plan review & P/E oversight (OCMI & MSC) Respond to Marine Casualties – issue deficiencies/ enforcement if appropriate Towing Company Will: Schedule inspection/drydock/ISE with local OCMI Make vessel available for inspection

TSMS Survey Programs External Surveys are conducted by TPO, which can be a Classification Society. Internal Surveys are conducted by trained personnel with a direct affiliation to the vessel, owner or managing operator. Internal Surveys, or examinations, can be completed in stages over time. Mix of two (internal topsides, external drydocking, etc) –flexibility to use TPO or Class Society in lieu of internal company resources or contracted surveyors.

Highlights what has to be done by a TPO…. TSMS Option Options within the Option Required for all TSMS Options Company (Management) Vessel External TSMS audit every 5 years by TPO External mid-period TSMS audit by TPO Annual internal management TSMS audits CG inspection for certification every 5 years Credit dry dock(s) and ISE(s) * * Dry docks/ISEs under the internal survey program can be a continuous event scheduled over time 137.315(c) Company choice (Options) – pick one...or...more... External Survey Program Internal Survey Program Annual vessel survey by a TPO Survey is a single event within 3 months of the COI date External drydock exam Annual vessel survey by company* Survey can be a continuous event scheduled over time (up to 1 year ) Internal drydock exams over time Highlights what has to be done by a TPO…. Surveys can be scheduled over time… Note: A CG accepted existing SMS or a fully compliant ISM SMS can be used to meet TSMS requirements 138.225

Approved Third Parties Will: Review/Approve/Oversee TSMS/ISM Issue TSMS Certificate – valid for 5 yrs Plan review & P/E oversight Survey/Audit Mid-period & TSMS issuance Mgmt Audit Annual Internal Mgmt Audit Vessel Audit once every 5 yrs Dry-dock/ISE & Annual Vessel Survey New Construction/Major Mod Survey Issue non-conformities & clear deficiencies issued by CG Document compliance/Submit required reports/Maintain records Towing Company Will: Develop/Implement SMS Coast Guard Will: Issue COIs – set routes & manning Review objective evidence/report(s) at COI Targeted exam – May attend annual survey, dry-dock or major non-conformities Respond to Marine Casualties – issue deficiencies/enforcement if appropriate Direct vessel and/or company audits as needed NCOE review TPO reports. Appeals

Approved Third Parties Will: Review/Approve/Oversee TSMS Issue TSMS Certificate – valid for 5 yrs Plan review & P/E oversight* Audit Companies & Vessels Mid-period & TSMS issuance Mgmt Audit Vessel Audit once every 5 yrs Oversee Company Internal Survey Program Issue non-conformities & clear deficiencies issued by CG Document compliance/Submit required reports/Maintain records Towing Company Will: Develop/Implement SMS Survey /Audit Dry-dock/ISE & Annual Vessel Survey Annual internal management TSMS audits Coast Guard Will: Same as TSMS External Survey Option

Initial COI 6 Months Before COI Inspection (If utilizing TSMS) If TSMS & company complies w/requirements, TPO audits management & vessel*. TPO issues company TSMS Certificate. Company maintains list of vessels under TSMS Certificate. 3 Months Before COI Inspection Company schedules initial COI inspection with OCMI. 30 Days Before COI Inspection Company submits Application for Inspection to OCMI. TSMS Vessels also submit Objective evidence to OCMI per 136.210 and 137.202. Initial COI Inspection Conducted by U.S. Coast Guard and a COI is issued. *Vessels external audit may be conducted 6 months after the COI if the vessel has been owned for less than 6 months

Benefits of a TSMS Flexibility Can be scaled for company size/type Rolling surveys Don’t have to schedule days/weeks in advance & potentially take vessel out of service TPO or Company role in drydocks/ISE/new construction/major modifications Accountability Establishes responsibility Continuous Compliance Consistency Clear, well defined procedures/roles Documentation Policy Planning Implementation & Action Checking & Corrective Action Management Review

Sub M – Third Party Organization (TPO) Third Party Will: Submit application to be an approved TPO Auditor and/or Surveyor Notify Surveyor/Auditor removal of employment Make available to the CG all required oversight elements Notify CG prior to conducting a 3rd Party “External” Management (Company) and Vessel Audits Submit External Audit results to CG CG Towing Vessel NCOE Will: Approve 3rd Parties Review/Approve 3rd Party Auditor/Surveyor Maintain list of approved TPOs Audit TPO once every 5 yrs Attend at least one External Management Audit for each TPO once every 5 yrs. Coordinate & advise on targeting/ performing oversight exams Suspend/Terminate TPO – appeal to CG-CVC Review Audit reports & place in MISLE Notify local OCMI of major non-conformities

Sub M – Existing Vessels Electrical requirements for existing vessels are minimal Major Modifications Owners/operators must maintain watertight integrity & stability Use of doublers will likely be accepted on certain routes & services – more guidance to follow Sub M lifesaving requirements above Sub C Flares Water light on life-ring on rivers Skiff allowed in Lieu of Rigged Inflatable inside three miles Corrected dates for New installations of pressure vessels on existing vessels - July 20, 2018 Trigger date for alterations or modifications that results in major conversion has been corrected to July 20, 2017. New installation that is not a ''replacement in kind'' - this requirement starting July 20, 2018 Limited Geographic Areas Worksite exclusions As noted in our discussion of comments on § 141.305, the Coast Guard does not agree with the assumption that the vessel and its tow operating more than 1 mile from shore could make it to shore in the event of an accident. Section 141.330 does not impose a separate requirement that ‘‘other survival craft’’ be carried: Instead it simply sets out the requirements for a skiff if the skiff is intended to be used as a substitute for approved survival craft required by Table 141.305. Table 141.305 prescribes the operating areas where an approved inflatable liferaft is required. As noted above, the Coast Guard has included additional text in § 141.305 prescribing the hierarchy of approved survival craft, and giving owners and operators the right to substitute a survival craft of higher precedence. For example, § 141.305(d)(3)(ii) allows an inflatable liferaft approved under approval series 160.051 or 160.151 to be substituted for an inflatable buoyant apparatus or rigid buoyant apparatus. Similarly, an inflatable buoyant apparatus approved under approval series 160.010 or life float under approval series 160.027 may be substituted for a rigid buoyant apparatus (§ 141.305(d)(3)(iii) and (iv), respectively). If the operator would prefer to use a non-approved raft as a survival craft, the functional requirements listed in § 141.305(b) would apply to the raft.

Sub M – Moving Forward Develop guidance – NVICs on TPO guide, compliance & implementation MSM Vol III manning – should be published in Federal Register in the next few days Towing Vessel Safety Advisory Committee – task statements Towing Vessel National Center of Expertise

Questions Capt Kevin Oditt USCG Eighth District Chief of Prevention 5/12/2018 Unclassified