1. 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 , slip law.
SEC 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

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.
The proposed rule is authorized by the Coast Guard and Maritime Transportation Act of 2004 (Pub. L ):
Sec. 415, INSPECTION OF TOWING VESSELS:
In paragraph (a), Congress amended 46 U.S.C by adding towing vessels to the list of vessels subject to inspection.
In paragraph (b), Congress amended 46 U.S.C 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 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 at 34.
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.
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

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.
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)

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 ) 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 , COAST GUARD AND MARITIME TRANSPORTATION ACT OF 2003, HOUSE REPORT NO :
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 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 at 34.

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.
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 , September 29, 2005 Report of the Working Group on Towing Vessel Inspection,  
Towing Vessel Inspection Working Group 9/06, Recommendation , 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 — Draft – TSAC Working Group Recommended Revisions
Report of the Towing Vessel Inspection WG, Recommendation , 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 , 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 (a): September 10, 2008 TSAC Economic Analysis Working Group Report
Economic Analysis Sub-Group Report (Towing Vessel Inspection), Recommendation (b): December 16, 2008 TSAC Economic Analysis Working Group Report
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
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.

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
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).

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
The applicability section for subchapter M is 46 CFR
Applicability;
(a) This subchapter is applicable to all U.S.-flag towing vessels as defined in § 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

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.
The applicability section for subchapter M is 46 CFR
Applicability;
(a) This subchapter is applicable to all U.S.-flag towing vessels as defined in § 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.

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.
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

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.
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

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.
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

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.
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

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).
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

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.
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.

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
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

18. A Bridge to Inspection…
Mr. Patrick Lee
Towing Vessel National Program Coordinator
Office of Vessel Activities (CG-5431)
6/19/2018

19. 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

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
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

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
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

22. 6/19/2018

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?
6/19/2018

25. Towing Vessel National Center of Expertise
6/19/2018

26. 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

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. 6/19/2018

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
6/19/2018

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
8 classes held so far
6/19/2018

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
6/19/2018

32. ?
6/19/2018