Towing vessel NATIONAL Center of Expertise

Towing Vessel National Center of Expertise So why were the NCOE created? As part of the Marine Safety Enhancement Plan, to increase marine safety competencies. CG became very security focused right after 9/11 and other mission sets, especially marine safety suffered somewhat. So this is CG’s plan to get us back on track. Our office officially opened in May 2010. We’re located in downtown Paducah. Towing Vessel National Center of Expertise

Towing Vessel National Center of Expertise STAFF Active Duty CDR Jacqueline Twomey LCDR Jaime Salinas LCDR Parris Stratton Civilian Roy Murphy Mike Kelly Steven Douglass Dave Phillips However, the real expertise and continuity resides with our civilians, which we have handpicked for just the right mix of experience and background. Roy is a licensed Master has been in the industry for over 30 years. He has been a member of MERPAC and TSAC, so he is like a walking encyclopedia of towing vessel and licensing knowledge from the industry perspective. He was also the director of the River Academy where he taught mariners, so he also brings a lot of instructional background and hence he is our School Manager. Mike is a retired LCDR and is also a Marine Inspector and Investigator. He investigated one of the most notable towing vessel casualties, the Elizabeth M. He was also the School Chief at the Yorktown marine safety school, so he brings a lot of CG instructional background to the unit. And he is our Information Technology guru and created our most excellent website. Steven graduated from the Massachusetts Maritime Academy and sailed for 12 years with K-sea towing as the Chief Engineer. So his formal education, practical experience and bluewater experience rounds out our staff so we can deliver our best to you. Dave is a retired CWO and is also a Marine Inspector and Investigator. ISO 9001 and 14001 lead auditor, RCP auditor, worked as SMS writer, auditor, security consultant and OSHA trainer for private company. Towing Vessel National Center of Expertise

Towing Vessel National Center of Expertise 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 Vision: Ensure consistent, professional, up to date enforcement of towing vessels regulations nation-wide that leads to enhanced safety, security, environmental stewardship and facilitation of commerce. Mission: Develop and provide instruction, design and deploy tools and present expert advice to influence policy, training and mission execution that is beneficial to the safe, secure and responsible operation of towing vessels. Towing Vessel National Center of Expertise

Professional Objectives Training Job Aids Policy & Guidance Technical Advice On-Site Assistance Liaison w/ Industry TRAINING – we develop and implement courses like the UTV course and other advanced courses in the future (like the Inspected Towing Vessel course). We provide OJT upon request. We can sign PQS as Verifying Officers and sit on Qualification Boards. JOB AIDS – We develop and oversee the jobs aids such as the exam form, guidebook and the Industry Indoctrination & Orientation Workbook. We just recently revised the exam form and the guidebook, which will be available for download from our website. We’re working on an Int’l Addendum to the exam form. We have ideas for future projects such as training videos, and maybe even an iphone app. POLICY & GUIDANCE – We assist Program Manager with development of policies and guidance. We helped shape all of the current UTV policies. And we’ve developed one for addressing pressure vessels that’s currently being reviewed at HQ. We also developed a process guide for navigating the Appeals, Exemptions & Equivalencies. TECHNICAL ADVICE - We interpret and clarify regulations, policy and guidance. We conduct extensive research into issue & provide technical advice & recommendations. ON-SITE ASSISTANCE –We provide on-site assistance. We can assist with novel UTV exams or high profile UTV casualty investigations. We can bring OJT to you or send your member here for OJT. We can participate in your unit industry days. LIAISON W/ INDUSTRY – We partner with industry and participate in CG-Industry workgroups like the Towing Vessel Safety Advisory Committee and the Bridging and Implementation Team. We conduct a lot of outreach thru functions like the Workboat Show and CG industry days. Thru all of these activities we stay in touch with the field, so when it comes to shaping policy it’s not done in a HQ vacuum. Towing Vessel National Center of Expertise

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

Bridge the gap – Ease the transition Purpose To ease towing vessel operators into an inspection regime To enhance, improve, & increase CG interactions with the towing industry To acclimate all stakeholders to the procedures, policy, & requirements of an inspection program To avoid disruptions to commerce when the regulations become effective Another way to put it, we’re doing a teeth cleaning not a root canal. Bridge the gap – Ease the transition Towing Vessel National Center of Expertise

Goals Towing Vessel Outreach, Orientation and Indoctrination Workbook Outreach to Industry & CG Examine 100% UTV Goal one is to Create an effective towing vessel industry orientation and indoctrination program for all new Coast Guard personnel assigned to Towing Vessel Examinations billets. Goal 2 - Create an outreach program designed to effectively communicate the Towing Vessel Bridging Program to all members of the towing industry and Coast Guard Goal 3 – Examine every UTV that will be inspected under Subchapter M during the Bridging Period. Doesn’t necessarily mean 100% decaled, but that just getting CG eyes on the boat makes the boat safer than it was before. We’re not just checking off boxes on the exam form, but we’re also educating and making the crews aware of the regulations, which are designed to make vessels safer. Towing Vessel National Center of Expertise

1 2 3 3 Phases Law Enforcement Boardings & Surge Operations Outreach & Education Qualification IIE’s UTV Course 1 Prioritized Exams 2 COI Issuance Advanced Course 3 Current Bridging Strategy Proposal (4 legged stool implemented in 3 Phases) Phase 1 Outreach Interaction between CG and Industry at all levels Learn each others cultures/get used to each other Education Indoctrination Program for all Examiners Complete Qualification Requirements Industry Scheduled Exams At Industry’s Convenience Goal – to get as many Tows/Tugs decaled as possible Phase 2 Risk-based Exams (Officer in Charge Marine Inspection (OCMI) prioritizes using Risk Tool, local knowledge, and vessel availability) Prior industry scheduled exam and issuance of a decal will exempt vessels from a risk based exam and will allow credit to be given when considering the scope of underway boardings. Formal Training to be developed during Phase 2, envisioned to be delivered at the Towing Vessel National Center of Expertise (TVNCOE) & Coast Guard Training Center (TRACEN) Yorktown Marine Inspection Course (MIC). Phase 3 Certificate of Inspection (COI) Issuance. We envision using risk-based tool developed in Phase 1 to assist in prioritizing the order of COI issuance conducted in Phase 3. Law Enforcement Boardings & Surge Operations Towing Vessel National Center of Expertise

UTV Fleet of Responsibility = 5571 Industry Initiated Exams = 5908 Prioritized 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

Towing Vessel National Center of Expertise Timeline COI 03/16 Final Rule (?) 2011 NPRM 2004 CG Auth Act Implementation [Draw on white board] Towing vessels have been uninspected since the 1800’s during the era of steam vessels. Due to a regulatory loophole, towing vessels have since been left out of the inspection program. However, though uninspected, they are still regulated. What does this mean? In 2004 the Maritime Transportation Act added Towing Vessels to the list of vessels subject of inspected vessels. Then the bridging program was developed collaboratively between CG and Industry to help facilitate the transition from uninspected to inspected status. NPRM imminent be careful not to inject proposed rules into your exams (proposed rules, not regulation yet) NPRM will most likely change by the time final rules come out we are still ensuring compliance with applicable regs, not proposed rules Final rule anticipated released approximately one year from NPRM. Then finally, there will probably be an implementation period before the rules become fully effective and and a COI is required to operate. 2009 TVBP Steamboat inspections 1800’s Towing Vessel National Center of Expertise

Compliance Phase-in Effective Date of Final Rule Full Compliance YR 11 Implement TSMS Prepare vessel etc. 25% Deferred Machinery & Electrical 5yrs fm COI Full Compliance 50% 75% 100% YR 11 6 3 4 5 YR 2 YR 8 YR 9 YR 10 This chart shows the compliance path for the proposed rule. The proposed rule phases-in the requirements to lessen the burden on the towing companies. After the final rule is issued, a company has two years to develop its TSMS, and three years to achieve compliance with Hours of Service and Crew Endurance Management Program requirements. The initial COI must be obtained within 4 years from the TSMS approval. For the cost estimates we assumed that 25% of the affected vessels would be approved in each year. Certain requirements for electrical and machinery systems, such as pilothouse alerter system and remote shutdown devices, were deferred until five years after the initial COI. Towing vessels moving oil or hazmat in bulk also have certain electrical and machinery requirements deferred until five years after the first COI. Towing Vessel National Center of Expertise

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

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

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. Posted on TVNCOE website Also contained in the revised Guidebook Thoroughly researched by TVNCOE staff Guidance sanctioned by CG-5431 TVNCOE Towing Vessel National Center of Expertise

Towing Vessel National Center of Expertise Policy Letter 10-06 Fixed CO2 Systems Issue 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 Allows designation of “Excess Equipment” for certain circumstances. Bill will discuss more in detail in his firefighting instruction. Towing Vessel National Center of Expertise

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

Towing Vessel National Center of Expertise Flexibility in the Law Equivalency Allowance for substitution or alternate equipment Exemption Relief from meeting specific regulations Appeals Relief from COTP/OCMI decision Appeals are used when industry disagrees with the CG’s finding regarding a particular issue such as an exemption Exemptions are meant to provide an avenue to not have to meet a particular regulation. Equivalencies are meant to provide an avenue to still meet a regulation, but using a different arrangement or piece of equipment to do it. Towing Vessel National Center of Expertise

Towing Vessel National Center of Expertise 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 Equivalencies are not granted at the COTP level like most exemptions. They must go to Commandant for determination. (a) If a particular item is required, Commandant may accept a substitution if satisfied by suitable trials that it is at least as effective as that specified in regulation. (b) If a particular item not required by law is unreasonable or impracticable, Commandant may permit use of alternate item as will insure safety consistent with the minimum standards set forth in regulation. Towing Vessel National Center of Expertise

Towing Vessel National Center of Expertise 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

Towing Vessel National Center of Expertise 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 Appeals are an avenue that industry can use when they do not agree with any decision made by a COTP or OCMI (a local command decision) including decisions regarding an exemption. Basic elements of an Appeal: 30-day time limit (can be extended upon written request and for good cause). Formal written request to the authority who made the decision that is being appealed. Must contain description of the decision/action and the reasons why that decision/action should be set aside or revised. Example: Examiner => OCMI/COTP => District => COMDT Towing Vessel National Center of Expertise

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

Towing Vessel National Center of Expertise Questions? Towing Vessel National Center of Expertise