U.S. Coast Guard Notice of Proposed Rulemaking Inspection of Towing Vessels Good morning. My name is Patrick Mannion, I am the Senior Regulatory Project Manage in the Vessel and Facilities Operating Standards at US Coast Guard Headquarters in Washington DC. I am a licensed Towing Master Oceans, and have served as both a Master and as an owner of a towing company. For Coast Guard Authorization Act of 2010, see Public Law 111-281, slip law. SEC. 701. RULEMAKINGS (c) TOWING VESSELS.—No later than 90 days after the date of enactment of this Act (15 Oct 2010), the Secretary shall issue a notice of proposed rulemaking regarding inspection requirements for towing vessels required under section 3306(j) of title 46, United States Code. The Secretary shall issue a final rule pursuant to that rulemaking no later than 1 year after the date of enactment of this Act. is a correlation between the slides and the preamble of the NPRM. Articulated tug-barge Nov 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. The proposed rule is authorized by the Coast Guard and Maritime Transportation Act of 2004 (Pub. L 108-293):   Sec. 415, INSPECTION OF TOWING VESSELS: In paragraph (a), Congress amended 46 U.S.C. 3301 by adding towing vessels to the list of vessels subject to inspection. In paragraph (b), Congress amended 46 U.S.C. 3306 by adding a paragraph stating “The Secretary may establish by regulation a safety management system appropriate for the characteristics, methods of operation, and nature of service of towing vessels.’’. Sec. 409, HOURS OF SERVICE ON TOWING VESSELS. Congress amended 46 U.S.C. 8904 stating “The Secretary may prescribe by regulation requirements for maximum hours of service (including recording and recordkeeping of that service) of individuals engaged on a towing vessel that is at least 26 feet in length measured from end to end over the deck (excluding the sheer).” Finally, on June 1, 1999, the National Transportation Safety Board issued Recommendation M-99-1 that stated the Coast Guard should “Establish within 2 years scientifically based hours-of-service regulations that set limits on hours of service, provide predictable work and rest schedules, and consider circadian rhythms and human sleep and rest requirements.” This section [Sec. 410] would give the Coast Guard the legal authority to implement these recommendations. H.R. REP. 108-233 at 34. 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. Towing vessels are a class of uninspected vessels. The Coast Guard does not issue Certificates of Inspection to uninspected towing vessels. A COI prescribing minimum manning and routes of operation   The Coast Guard does have regulatory authority over these vessels, however. Towing vessels are covered by regulations; Specific to towing vessels (33 CFR 163) TOWING OF BARGES Applicable to all uninspected vessels (46 CFR Subchapter C), UNINSPECTED VESSELS and General rules that apply to all vessels under CG jurisdiction (33 CFR part 83, 75 FR 19546, Apr. 15, 2010). INLAND NAVIGATION RULES The Coast Guard has the authority to board towing vessels to conduct safety and security examinations (14 U.S.C. 89). 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. The CG’s 2004 notice, request for comments, and notice of public meetings titled “Inspection of Towing Vessels” was published December 30, 2004 (69 FR 78471). Public meetings were held in Washington, DC; Oakland, CA; New Orleans, LA; and St. Louis, MO. The American Bureau of Shipping Group (ABSG) Consulting Inc. final report entitled “Uninspected Towing Vessel: Industry Analysis Project” was issued in August 2006. Recommendations; (186 page report) 1. Consider excluding workboats and towing assistance vessels from the proposed regulations for inspection of towing vessels. (See Section 6.2.1) 2. Ensure that large horsepower towing vessels (i.e., greater than 5,000 horsepower) receive the regulatory attention they deserve based on historical accident experience examined in risk terms. (See Sections 6.1 and 6.2.2) 3. Consider providing effective training when the final rule for the towing vessel inspection regulation is released and then providing periodic training for Coast Guard inspectors and third-party personnel who will be involved in towing vessel inspections, in order to help ensure consistency in regulatory review and enforcement. (See Section 6.2.3) 4. Consider encouraging small business outreach/assistance programs by industry organizations or by the Coast Guard to assist small towing companies in SMS development and implementation, both for compliance purposes and to help them achieve real human factors improvements. (See Section 6.2.4) 5. Consider offering alternative inspection approaches (i.e., that do not require a company safety management system) for companies that prefer being subject to a more prescriptive inspection regime. (See Section 6.2.5)

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. In its March 23, 2005 letter (USCG-2004-19977-115) submitted to the docket in response to our 2004 solicitation for comments, AWO stated that it shared “the agency’s conviction that establishing an inspection program for towing vessels centered on the requirement for a safety management system is the best way to improve safety, security, and environmental protection throughout the tugboat, towboat, and barge industry.” Legislative History from P.L. 108-293, COAST GUARD AND MARITIME TRANSPORTATION ACT OF 2003, HOUSE REPORT NO. 108-233: In September 2001, a towing vessel struck a bridge at South Padre Island, TX. The bridge collapsed and 5 people died when their cars or trucks went into the water. Less than 9 months later, on May 26, 2002, a towing vessel struck the I-40 highway bridge over the Arkansas River at Webber Falls, OK. The bridge collapsed and 14 people died when their cars or trucks went into the Arkansas River. As a result of these accidents, the Coast Guard and the American Waterways Operators established a joint working group to examine the statistics of bridge allisions and measures that could be taken to help prevent these types of casualties. The study used a database of 2,692 bridge allision cases between 1992-2001. One of the recommendations of the working group's May, 2003 report is to “require the implementation of Crew Endurance Management Systems (CEMS) throughout the towing industry as a means of improving decision making fitness.” In addition, on June 1, 1999, the National Transportation Safety Board issued Recommendation M-99-1 that stated the Coast Guard should “Establish within 2 years scientifically based hours-of-service regulations that set limits on hours of service, provide predictable work and rest schedules, and consider circadian rhythms and human sleep and rest requirements.” This section [Sec. 410] would give the Coast Guard the legal authority to implement these recommendations.   H.R. REP. 108-233 at 34.

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. In conjunction with the public Notice and the comments received, the Coast Guard began a collaborative project with Towing Safety Advisory Committee to;   Identify the elements that should be included in a safety management system Recommend a framework for Coast Guard oversight and enforcement of a towing vessel inspection program Consider whether any towing vessels should be exempt from coverage under an inspection program based on a safety management system Provide feedback to the Coast Guard as needed on issues and questions that arise during the rulemaking process. At the Coast Guard’s request, TSAC established two working groups (sub-committee)s consisting of members from industry, labor, class societies, auditors, and the general public to review the CG’s marine casualty database, to analyze the data and identify trends. Using Risk Based Decision Making methods, the working groups provided a general analysis of the data and identified trends to the Committee. The working groups played a key role in providing general information on risk analysis and in identifying major areas of identified “root causes” for the accident data. These identified causes were divided into the following categories: Human factors: situational awareness, task performance, navigation errors, lookout, and voyage planning. Equipment failures, involving all systems: propulsion, cables and lines, electrical, hull, fuel, steering, cargo/deck machinery. The remainder were external (outside of the control of the vessel or company): extreme weather, the actions of other vessels. All these identified risk factors are addressed in the proposed rule. The full TSAC committee reviewed and approved all the working group reports. Accident data review findings source is “REPORT OF THE TOWING SAFETY ADVISORY COMMITTEE WORKING GROUP ON TOWING VESSEL INSPECTION, TASK #04-03, INSPECTION OF TOWING VESSELS. Dated SEPTEMBER 7, 2006” The Towing Safety Advisory Committee (TSAC) is a federal advisory committee that works with the CG on towing industry safety. Towing Safety Advisory Committee Task Statement #04-03  Towing Vessel Inspection Working Group 9/05, Recommendation 128-05, September 29, 2005 Report of the Working Group on Towing Vessel Inspection,   Towing Vessel Inspection Working Group 9/06, Recommendation 133-06, September 7, 2006 Report of the Towing Safety Advisory Committee Working Group on Towing Vessel Inspection, Task #04-03 Inspection of Towing Vessels Towing Vessel Inspection Redline, Recommendation 135-07— Draft – TSAC Working Group Recommended Revisions 05-21-07 Report of the Towing Vessel Inspection WG, Recommendation 138-08, March 24, 2008 Towing Vessel Inspection Working Group Review of Revised Draft Regulatory Text Initial report of Economic Analysis Sub-Group for Towing Vessels, Recommendation 140-08, September 10, 2008 Memo re TSAC Economic Analysis Working Group Report Report of the Economic Analysis Sub-Group of the Towing Vessel Inspection Working Group, Recommendation 140-08(a): September 10, 2008 TSAC Economic Analysis Working Group Report Economic Analysis Sub-Group Report (Towing Vessel Inspection), Recommendation 140-08(b): December 16, 2008 TSAC Economic Analysis Working Group Report 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 The proposed rule called for by the Coast Guard and Maritime Transportation Act of 2004 was developed in cooperation with TSAC. TSAC established a working group that had membership from industry, labor, class societies, auditors, and the general public. TSAC reviewed and approved the working group’s reports. Results; Creates a new 46 CFR subchapter M consisting of parts 136 thru 144: 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   We also make necessary revisions to existing regulations in: Part 2 – VESSEL INSPECTIONS and Part 15 – MANNING REQUIREMENTS. Establishes baseline regulations for inspected towing vessels. Defines the Towing Safety Management System (TSMS). The Coast Guard has proposed approval procedures for third-party TSMS auditors and surveyors, to carry out routine compliance activities under Coast Guard oversight. The Coast Guard believes that using third parties to carry out compliance activities provides the maximum flexibility in that it reduces vessel downtime, provides greater flexibility in scheduling inspections, and provides greater flexibility in meeting required standards. Third-party auditors would review and approve the TSMS and ensure that it complies with the proposed requirements. Third-party auditors would also conduct required external audits of a TSMS to verify that the system functions as intended. In instances when the regulations require the use of a surveyor, an approved third-party surveyor would be required, providing independent technical expertise to examine the vessel, its systems, and equipment. Prescribes procedures for vessel compliance and obtaining a COI.

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 We discuss these elements of the proposed rule in the preamble, followed by a part-by-part analysis of the new 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 We also make necessary revisions to existing regulations in PART 2 – VESSEL INSPECTIONS and Part 15-MANNING REQUIREMENTS. The International Safety Management (ISM) Code is required for certain-sized towing vessels that engage in international voyages. It can also be used on a voluntary basis by other towing vessels. The Responsible Carrier Program, RCP, is a proprietary system used by companies that are members of the American Waterways Operators (AWO). Members of AWO are required to use RCP, but it is not used by companies outside of AWO. Some towing companies use both systems, one required by law/regulation (ISM) and one required by their membership in AWO (RCP).

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 The applicability section for subchapter M is 46 CFR 136.105 . Applicability;   (a) This subchapter is applicable to all U.S.-flag towing vessels as defined in § 136.110 engaged in pushing, pulling, or hauling alongside, except: (1) A vessel less than 26 feet (8 meters) in length measured from end to end over the deck (excluding the sheer), unless pushing, pulling, or hauling a barge that is carrying dangerous or hazardous materials; (2) A vessel engaged in one or more of the following: (i) A vessel used for assistance towing; (ii) A vessel towing recreational vessels for salvage; or (iii) A vessel transporting or assisting the navigation of recreational vessels within and between marinas and marina facilities, within a limited geographic area, as defined by the local Captain of the Port (COTP). (3) Work boats operating exclusively within a worksite and performing intermittent towing within the worksite; (4) Seagoing towing vessels over 300 gross tons subject to the provisions of Subchapter I of this chapter; (5) A vessel inspected under other subchapters of this chapter that may perform occasional towing; (6) A public vessel that is: (i) Owned, or demise chartered and operated by, the U.S. government or by a government of a foreign country; or (ii) Not engaged in commercial service. (7) A vessel which has surrendered its Certificate of Inspection (COI) and is laid up, dismantled, or otherwise out of service; and (8) A propulsion unit used for the purpose of propelling or controlling the direction of a barge where the unit is controlled from the barge, not normally manned, and not utilized as an independent vessel. (b) A vessel that is otherwise exempt from inspection may request application of this part. 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. The applicability section for subchapter M is 46 CFR 136.105 . Applicability;   (a) This subchapter is applicable to all U.S.-flag towing vessels as defined in § 136.110 engaged in pushing, pulling, or hauling alongside, except: (1) A vessel less than 26 feet (8 meters) in length measured from end to end over the deck (excluding the sheer), unless pushing, pulling, or hauling a barge that is carrying dangerous or hazardous materials; (2) A vessel engaged in one or more of the following: (i) A vessel used for assistance towing; (ii) A vessel towing recreational vessels for salvage; or (iii) A vessel transporting or assisting the navigation of recreational vessels within and between marinas and marina facilities, within a limited geographic area, as defined by the local Captain of the Port (COTP). (3) Work boats operating exclusively within a worksite and performing intermittent towing within the worksite; (4) Seagoing towing vessels over 300 gross tons subject to the provisions of Subchapter I of this chapter; (5) A vessel inspected under other subchapters of this chapter that may perform occasional towing; (6) A public vessel that is: (i) Owned, or demise chartered and operated by, the U.S. government or by a government of a foreign country; or (ii) Not engaged in commercial service. (7) A vessel which has surrendered its Certificate of Inspection (COI) and is laid up, dismantled, or otherwise out of service; and (8) A propulsion unit used for the purpose of propelling or controlling the direction of a barge where the unit is controlled from the barge, not normally manned, and not utilized as an independent vessel. (b) A vessel that is otherwise exempt from inspection may request application of this part. 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. Safety Management System; The International Safety Management (ISM) Code is required for certain-sizes of towing vessels that engage in international voyages. It can also be used on a voluntary basis by other towing vessels. The Responsible Carrier Program, RCP, is a proprietary system used by companies that are members of the American Waterways Operators (AWO). Members of AWO are required to use RCP, but it is not used by companies outside of AWO. Some towing companies use both systems, one required by law/regulation (ISM) and one required by their membership in AWO (RCP).   USCG Inspection Option: Traditional regime for ensuring safe operations and compliance. Provides flexibility and possible cost savings for some. The proposed rule is risk-based; a subgroup of the TSAC working group conducted an analysis of towing vessel accident data and consulted with experts to identify risk factors in the towing industry. The proposed rule addresses all the identified risk factors. For human factors there are requirements for training, safety drills, crew endurance management program, and hours of service requirements for crew members. For equipment failures the proposed rule has specific requirements for lifesaving, fire protection, electrical and machinery systems and their components, and vessel operational requirements. Recordkeeping requirements for training, drills, equipment installation, and maintenance provide the documentation needed for management of the TSMS by the company and oversight by third-parties and the CG. The TSMS, combined with the audits, surveys, and CG oversight, defines a dynamic safety system at the vessel and company levels. 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. Here is how all the components work together: The Coast Guard approves the third-parties, the auditors and surveyors. The owners/operators of towing vessels develop and implement a TSMS tailored to their operations and ensure that their vessels meet the regulatory standards. The third parties verify compliance by auditing the TSMS and conducting surveys of the vessels. This is complemented by CG inspections for both the initial COI, the renewals, and as deemed necessary by CG review of accident history and other risk factors. The CG reviews the reports and, if all is satisfactory, issues the initial Certificate of Inspection and subsequent renewals. 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. The owners and operators of towing vessels must develop and implement a TSMS that meets the requirements for both vessels and shore-side operations. The company must operate under its TSMS. The vessels must be maintained in compliance with regulatory standards and the company’s 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. The approved third-party auditors and surveyors review and approve a company’s TSMS, audit the TSMS and vessels, and survey the 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). Reviewing the concept by responsibilities of each party: The CG is responsible for approval and oversight of the third party auditors and surveyors, and a physical (“Boots on the deck”) inspection of every towing vessel at least once every five-years. The CG may perform additional boardings as indicated by review of risk factors. The CG issues the initial COI and renewals. 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. 5,208 towboats and tugboats would be affected by the rule. They are diverse both in terms of geography and the work they do. They operate on inland rivers, the Great Lakes, the coasts of the Atlantic and Pacific Oceans and the Gulf of Mexico, and the larger ones engage in international trade across the oceans. Towing vessels move barges containing bulk commodities such as grain, coal, petroleum and petroleum products, and chemicals. Towing vessels also move deck barges carrying heavy equipment, including derricks cranes and specialty equipment for the construction, salvage, and dredging industries. They also move oversized equipment like power plant turbines and spacecraft. Smaller towboats work the fleeting areas on the inland rivers where the tows are assembled and broken-up. In inland and coastal harbors towing vessels perform ship assist work, moving the larger ships into and out of the berths and escorting them in the harbors, and moving the bunker or fuel barges. At the company level, the proposed rule would affect 1,059 companies that own and/or operate towing vessels. (Chartering or leasing of vessels is common in the industry). Of these 1,059 companies, 327 of them currently operate with an audited safety management system and control 2,941 towing vessels. The other 827 companies control 2,267 vessels and operate without an audited safety management program.

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 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. 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 6/19/2018

Towing Vessel Bridging Program Why do we need a bridge? Admiral Watson, Director of Prevention Policy (CG-54) tasked Domestic Vessel Compliance Division (CG-5431) with developing, with industry input, a Towing Vessel Bridging Strategy to ease the transition of towing vessel operators into a Coast Guard inspection regime. We plan to do this by enhancing, improving, and increasing Coast Guard interactions with the towing vessel industry, and by acclimating all involved with the procedures, policy, requirements and administration of an inspected program, so disruptions to commerce can be avoided when the regulations become effective. 6/19/2018

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 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 6/19/2018 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 During Phase 1 we attained recourses to start the program including 108 dedicated billets, establishment of the TVNCOE, funding for training. Phase 2 will not start until after the policy has been developed & disseminated, training is complete, and all of the Areas & Districts indicate they are ready to commence Phase 2 activities. Phase 1 activities do NOT stop when Phase 2 starts. 6/19/2018

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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? 6/19/2018

Towing Vessel National Center of Expertise 6/19/2018

Why is the Center of Expertise in Paducah? Hub of the inland waterways Tow Boat City USA Seamen’s Church Institute Hub of the inland waterways - Paducah is located at the confluence of the Tennessee and Ohio Rivers, and close to the confluence of the Cumberland and Mississippi Rivers Tow Boat City USA –The densest population of industry and towing vessels in the country. About 2 dozen barge companies have headquarters or major operations centers in Paducah and well over 70% of the nations towing vessels are located in the inland river and Gulf Coast regions. Seamen’s Church Institute – largest mariners’ agency in North America, trains hundreds of mariners each year in only 2 locations – Houston and Paducah 6/19/2018

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 6/19/2018

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 8 classes held so far 6/19/2018

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 6/19/2018

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