1. U.S. Coast Guard Notice of Proposed Rulemaking
Inspection of Towing Vessels
Articulated tug-barge Sept 2011

2. 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

3. 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

4. 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.

5. 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.

6. 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

7. 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

8. 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

9. 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

10. 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.

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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.

17. 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

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

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

20. 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

21. 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

22. 4/19/2017

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

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

25. Towing Vessel National Center of Expertise
4/19/2017

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

27. 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

28. 4/19/2017

29. 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

30. 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

31. 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
4/19/2017

32. ?
4/19/2017