1. Sub M - Implementation 1

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

3. 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

4. Compliance Timeline Deferred Equipment
YR 0
YR 1 & 2
YR 3
YR 4
YR 5
YR 6 YR
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 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

5. 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

6. 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)

7. 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

8. 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.

9. 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 (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

10. 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

11. 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

12. 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 and
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

13. 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

14. 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

15. 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 § , 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 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 Table prescribes the operating areas where an approved inflatable liferaft is required. As noted above, the Coast Guard has included additional text in § prescribing the hierarchy of approved survival craft, and giving
owners and operators the right to substitute a survival craft of higher precedence. For example, § (d)(3)(ii) allows an inflatable liferaft approved under approval series or to be substituted for an inflatable buoyant apparatus or rigid buoyant apparatus. Similarly, an inflatable buoyant apparatus approved under approval series or life float under approval series may be substituted for a rigid buoyant apparatus (§ (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 § (b) would apply to the raft.

16. 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

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