U.S. Coast Guard Notice of Proposed Rulemaking Inspection of Towing Vessels Articulated tug-barge Sept 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/operations are 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 safety and 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 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.

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 for inspected towing vessels. Defines the Towing Safety Management System (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. TSMS + audits, surveys, and CG oversight = a dynamic system. 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 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

A Bridge to Inspection… Mr. Patrick Lee Towing Vessel National Program Coordinator Office of Vessel Activities (CG-5431) 202-372-1135 4/19/2017

Towing Vessel Bridging Program Why do we need a bridge? 4/19/2017

Law Enforcement Boardings & Surge Operations A Phased Approach… Phase 2 Prioritized Exams Course Development Comments on NPRM 100% FORs examined Phase 3 COI Issuance Formal Training Phase 1 Outreach & Education IIEs Testing of Risk Tool Qualification/PQS Id of FORs Subchapter “M” Published Summer 2009 Law Enforcement Boardings & Surge Operations 4/19/2017 20

Phase 2 Prioritization Matrix High Priority Vessel Company has not participated in Phase 1 Vessel has not been examined Low Priority Vessel Company participating in Phase 1 Non-Priority Vessel Vessel has been examined 4/19/2017

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UTV Fleet of Responsibility 117 313 225 415 3955 343 158 347 66

Towing Vessel National Center of Expertise What is it? Who is it? What can it do for me? 4/19/2017

Towing Vessel National Center of Expertise 4/19/2017

Why is the Center of Expertise in Paducah? Hub of the inland waterways Tow Boat City USA Seamen’s Church Institute 4/19/2017

The TVNCOE Team Active Military: Civilians: LCDR Russell LCDR Bethke LCDR Keogh Supervisor Asst. Supervisor Inspector COE Manager Asst. Manager Investigator Inspector Inspector Civilians: Roy Murphy Steven Douglass Bill Perkins Mike Kelly Industry Industry USCG retired USCG retired Licensed Master Licensed Master Inspector Inspector Training Chief Engineer Investigator Investigator

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CG’s Experts on Towing Vessels Training Assist in the development of curriculum Improve consistency of exams, inspections Information brokers Gather, organize, distribute important data Subject Matter Expertise Identify issues and help shape policy Bring the industry and Coast Guard together 4/19/2017

Campbell Transportation Co Training UTV Examiner Course Total = 8 (FY10 & FY 11) CG Students trained = 152 Industry reps participated = 52 Companies represented = 33 Other Outreach Firefighting Pressure vessel AEP River Operations Golding Barge Line Marathon Oil Ingram United Barge Line Campbell Transportation Co Kirby Corp Vane Brothers Hunter Marine Foss Maritime Co Penn Maritime, Inc Canal Barge Co MarCom 4/19/2017

TVNCOE Website www.uscg.mil/tvncoe Quick access to towing vessel information Centralized location for current CG policies, guidebooks, PQS manual, job aids, etc Links to other resources News & Events www.uscg.mil/tvncoe 4/19/2017

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