A Bridge to Inspection… Mr. Patrick Lee Towing Vessel National Program Coordinator Office of Vessel Activities (CG-5431) CDR Greg Case Detachment Chief Towing Vessel National Center of Expertise Ms. Lynn Muench Senior Vice President- Regional Advocacy American Waterways Operators 11/14/2018

Partnerships CG & Industry partnered workgroups Monitor various processes of the Towing Vessel Bridging Program (TVBP) WG#5 – general monitoring of TVBP WG#6 – Industry input for TVNCOE WG#7 – Phase 2 Another key activity has been our role in being a part of and strengthening partnerships throughout the industry. An example is our leadership role in several CG/Industry workgroups which were stood up to help progress through the TVBP. These include the Bridging and Implementation Team workgroups. Presently 4 have completed their work and 3 are active. WE play a key or lead role in all 3 groups.

Current and Future Initiatives Workgroups comprised of Coast Guard, AWO, & Industry members worked on the following items in 2010. Policy LTR 10-02, Existing Systems and Equipment. Policy LTR 10-05, Electronic Nav Pubs. Policy LTR 10-06, Carriage of Excess Equipment. Refined TVBP Tools. Development of Flow Chart & Examples for Appeal, Equivalency & Exemption submissions. Phase 2 Implementation Strategy, Policy & Guidance. In 2011 these work groups will focus on: Perko Navigational Light Fixture Policy. Con’t development of Phase 2 Policy & Tools. Amend the Outreach, Orientation & Indoctrination workbook. Re-write the towing vessel examination form. 11/14/201811/14/2018

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. 11/14/2018

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Current compliance issues After nearly 2500 uninspected towing vessel exams, some key issues have surfaced. Current compliance issues 11/14/2018

Unfired Pressure Vessels (UPV) E.g. engine start/clutch air recievers Currently not regulated by CG Problem: found some UPVs may present a “hazardous condition” which could seriously injure crewmembers Missing or improperly rated relief valve Missing data plate or documentation to prove that the tank was built to a standard Improper maintenance and/or repairs 11/14/2018

Problems Found 11/14/2018

Problems Found 11/14/2018

Safety Alert Air Receivers and Relief Valves Issue identified during UTV Exams Hazardous Condition Issue Jurisdictional Questions Joint effort between USCG Office of Investigations and Analysis and the TVNCOE Educational Tool During the course of examining towing vessels, UTV examiners are finding issues where there appears to be no clear regulatory guidance on which the examiner can rely. Many of these are resolved on site . However, there are some that are so pervasive that they require a national approach. Unfired Pressure Vessels (Air Receivers) is an example. Examiners are finding issues which clearly pose safety hazards for personnel who work in spaces where these PV are housed. And, depending on their function, could also pose a risk to operational safety.

Navigation Lights 46 CFR 25.10 Vessels built after Nov. 7, 2002 are required to be fitted with certified nav lights. Any certified fixture that is modified to fit any bulb other than what’s specified for use by manufacturer voids the certification. “certified” by a laboratory listed by CG to the standards of ABYC A-16 or equivalent. We have seen numerous vessels that have modified fixtures to use household bulbs. 11/14/2018

Fixed CO2 Fire Suppression Systems Must be type approved or accepted by CG IAW 46 CFR 25.30-15 Must be installed IAW 46 CFR 76.15 11/14/2018

Inadequate amounts of CO2 to protect the space. Problems Found CO2 systems with over 300lb capacity are located inside the space being protected. Inadequate amounts of CO2 to protect the space. 11/14/2018

HillerSAFE Fire & Bilge Flooding Alarm System Found on some towing vessels This system is not considered to be an engine-room monitoring system. Not CG approved or listed by independent testing laboratory Hiller Systems Inc is currently working with FM Approvals LLC to conduct the required testing of the system in an attempt to be listed and/or CG approved. This system should not be installed on towing vessels until it is listed and/or CG approved. HILLERSAFE FIRE DETECTION SYSTEMS ON UNINSPECTED TOWING VESSELS (Marine Inspection Note 01-10)   While conducting Industry Initiated Exams, U.S. Coast Guard Marine Inspectors and Towing Vessel Examiners have discovered HillerSAFE Fire and Bilge Flooding Alarm systems installed on board uninspected towing vessels that do not meet the requirements of Subchapter C. Hiller’s literature (attached) advertises these systems as having been tested to Lloyds Register (LR) Test Approval System, Test Specification1 by Retlif Testing Laboratories. Title 46 Code of Federal Regulations (CFR), Part 27, Subpart B – Fire Protection Measures for Towing Vessels, establishes requirements for fire detection on towing vessels. Specifically 46 CFR 27.203(a) requires each detector, each control panel, and each fire alarm (the fire detection system) to be Coast Guard approved or listed by an independent testing laboratory; EXCEPT that, if you use an existing engine-room monitoring system (with fire detection capability), only the detectors must be listed by the independent laboratory. 46 CFR 27.203 allows the use of existing engine-room monitoring systems (with fire detection capability) on towing vessels whose construction was contracted for before January 18, 2000. USCG approved fire detection systems can be found under Approval Series 161.002 in MISLE and CGMiX at: http://cgmix.uscg.mil/Default.aspx The regulatory intent of “listing by an independent testing laboratory” is to allow NFPA 72 compliant fire detection equipment without requiring the additional testing required for USCG type approval. There are three national independent laboratories providing listing or labeling programs for fire detection equipment complying with NFPA 72. These laboratories and their marks are as follows: FM Approvals LLC (FM), phone: 781-762-4300 Their mark is the letters FM within a diamond above the word Approved. Intertek Testing Services NA, Inc. (ITSNA), phone: 800-345-3851 Their mark is the letters ETL inside a circle with the letters US to the side. The word “listed” will break the bottom of the circle. The name INTERTEK will appear beneath the circle. There may be additional letters for coverage outside the US. Underwriters Laboratories Inc. (UL), phone: 847-272-8800 Their mark is the letters UL inside a circle with the letters US to the side. There may be additional letters for coverage outside the US. Retlif Testing Laboratory is accepted by CG-5214 for providing reports of tests to the marine environmental standards such as Lloyds Register (LR) Test Approval System, Test Specification 1. Retlif neither conducts the fire detection component tests nor provides a listing service for fire detection equipment. The HillerSAFE Fire and Bilge Flooding Alarm System is not considered to be an engine-room monitoring system. Because it is not used regularly, a bilge alarm system cannot be considered as reliable as a system used to monitor the engines and critical machinery. Hiller Systems Inc. is currently working with FM to conduct the required testing of the HillerSAFE system to be listed and/or Coast Guard approved. Consistent with the philosophy of CG-543 Policy letter 10-02, until this testing is complete, do not issue requirements to owners to remove HillerSAFE systems as long as they are operating properly. Instead, place an inspection note in MISLE, valid for one year, stating “This vessels fire detection system does not currently meet the requirements of 46 CFR 27.203(a). Inspectors/Examiners should not require this equipment to be removed until the testing is complete and a determination has been made on this system meeting the acceptable standards.” A towing vessel decal should not be issued until this issue is resolved. CG-5214 will oversee the testing progress. Periodic updates on the progress of the HillerSAFE system testing will be given to Area and District Towing Vessel Coordinators. Once final determination has been made, an updated Marine Inspection Notice 01-10 will be distributed to the field with the testing outcomes and further guidance. Questions concerning this notice may be directed to Mr. Patrick Lee in the Office of Vessel Activities, Domestic Compliance Division (CG-5431) at Patrick.j.lee@uscg.mil 202-372-1135 or Mr. Louis Nash at Coast Guard Headquarters Lifesaving and Fire Safety Division (CG-5214) at (202) 372-1388. 11/14/2018

Fuel Shut-Off Valves 46 CFR 27.207 Positive remote fuel shut-off valve Near source of supply Remotely operable outside the space (i.e. reach-rod, pull cable) A positive remote fuel shut-off valve is required to be fitted on any fuel line that supplies fuel directly to an engine or generator. Valve must be near source of supply (e.g. at the day tank, storage tank, or fuel distribution manifold) Valve must be operable remotely in a safe place outside the space the valve is installed. The remote valves can be reach-rod or steel pull cable Problems: shut-off valves located at the engine instead of near the fuel tank; pneumatically controlled remote valves; shut-off valves installed inside the tank 11/14/2018

Valve installed at the engine instead of near the tank. Problems Found Valve installed at the engine instead of near the tank. Valves not functional Valves not labeled properly The intent of the regulations is to install these valves at the source of fuel, such as a day tank, so that in the event there’s a break in the fuel line the crew can stop the flow of fuel. The purpose is to prevent a devastating engine room fire. 11/14/2018

Possible Alternative Solutions Appeals, exemptions and equivalency requests which enable written policy Appeals = request for relief from Captain of the Port (COTP) decision Exemption = written requests to COTP for relief from meeting a specific regulation Equivalency = written request to Commandant for substitution or alternate equipment 11/14/2018

Questions? 11/14/2018