1. Welcome to a Towing Vessel Conversation USCG Sector Honolulu Prevention Department

2. Topics for discussion TVBP (Past, Present and Future) UTV Exam Form UTV “C” School Subchapter M, NPRM – Comments – Public Meetings – Overview – Timeline

3. Towing Vessel Bridging Program Past – Coast Guard and Maritime Transportation Act of 2004 – Phase I, Summer 2009, Outreach, Education, Qualification, Industry Initiated Exams Present – 62 Vessels, 23 decals (37%), 45 examined (73%) Future – Phase II, ETA… Priority Based Exams, Continue Phase I, underway boardings, PSIX visibility for Priority Based Exam deficiencies – Decal expiration (3 year) – Phase III, COI issuance TVBP Homeport link

4. Priority Based Exams Company has not participated in Phase 1 Vessel has not been examined High Priority Vessel Company participating in Phase 1 Vessel has not been examined Low Priority Vessel Company participated in Phase 1 Vessel has been examined Non-Priority Vessel Note – Deficiencies identified during priority based exams (not IIEs) will be publically available through PSIX

5. UTV Exam Form Changes from old form – New Requirement for UTVs guidebook – Changes to exam item locations/groupings – CEMS removed – Additional statuses on first page – Separate recommendations and deficiencies pages – New Instructions form

6. UTV “C” School Yorktown, VA Paducah, KY Exportable http://www.uscg.mil/hq/cg5/TVNCOE/Course s.asp http://www.uscg.mil/hq/cg5/TVNCOE/Course s.asp

7. NPRM Subchapter M – Comments Online or in writing Comments and related material must be submitted to the online docket on or before December 9, 2011 Identify comments by inserting Docket Number USCG-2006-24412 in the “docket ID” box Federal eRulemaking Portal http://www.regulations.gov http://www.regulations.gov

8. Subchapter M – Public Hearings Dates and Locations – Tuesday, 18 Oct – Newport News, VA – Monday, 24 Oct – St. Louis, MO – Wednesday, 26 Oct – Kenner, LA – Wednesday, 16 Nov – Seattle, WA Webcasts - http://www.towingvesselregs.us/http://www.towingvesselregs.us/ http://www.uscg.mil/msib/docs/043_11_9-9- 2011.pdf http://www.uscg.mil/msib/docs/043_11_9-9- 2011.pdf

9. NPRM – Overview Preamble – Public Participation and request for comments – Abbreviations – Background – Discussion of Proposed Rule & CEMS / Work rest – Incorporation by Reference – Regulatory Analysis

10. Subchapter M – Parts 136 – Certification 137 – Vessel Compliance 138 – Towing Safety Management System 139 – Third-party Organizations 140 – Operations 141 – Lifesaving 142 – Fire Protection 143 – Machinery and Electrical Systems and Equipment 144 – Construction and Arrangement

11. Applicability Applicability – All towing vessels (commercial, engaging or intending to engage in pulling, pushing, hauling along side or any combination thereof) Exceptions – Less than 26 feet, unless towing barges carrying dangerous or hazardous materials – Assistance towing – Vessels towing recreational vessels for salvage – Vessels transporting or assisting navigation of recreational vessels within and between marinas and marina facilities within a limited geographic area – Workboats operating exclusively in a worksite – Seagoing towing vessels > 300 GRT – Vessels otherwise inspected that “may perform occasional towing” – Public vessels – Vessels that surrendered COI and is laid up, dismantled or otherwise out of service – Propulsion units used to propel or control direction of a barge (controlled from the barge, not normally manned, not used as independent vessel)

12. Certification All COIs issued by USCG (5 year validity) Options for certification – Annual USCG inspection – Towing Safety Management System (TSMS) with use of approved 3 rd parties Specify option when applying for each COI (may be different for each vessel) Drydock/Internal Structural Exam – twice in 5 years, no more than 36 months (for all vessels exposed to salt water more than 6 months per year)(once in 5 otherwise) UWILD option available 46CFR137.335

13. USCG Option Owner/Operator schedules with OCMI Annual inspection +/- 3 months of anniversary – Similar but less detailed than COI issue/renewal May include any tests or inspections deemed necessary to evaluate seaworthiness Deficiencies documented with timeframe on CG- 835 Periodic inspection (full) at +/- 3 months of 2 nd or 3 rd anniversary (takes place of annual)

14. What is an approved 3 rd party? Organization approved by the USCG to carry out functions related to ensuring that TVs comply with the provisions of Sub M (audits, TSMS certificates, surveys, reports) Must be independent of the owner, managing operator and vessels they will be acting as 3 rd party for Must meet all the requirements of 46CFR139 Recognized classification societies (46CFR8) are prequalified 46CFR139.110

15. TSMS Option Obtain TSMS Certificate from 3 rd approved party within 2 years of final rule (5 yrs expiration) TSMS must meet requirements of 46 CFR138 ISM is deemed in compliance 46CFR138.225 Internal audits conducted annually +/- 3 months of TSMS certificate External (3 rd party) audits prior to TSMS certificate issuance and renewal External management audit between 27 th and 33 rd month External audit of each vessel during 5 year period (TSMS cert) Annual External audits of vessel 137.205 Notify USCG prior to conducting 3 rd party audit Submit results to USCG

16. This chart shows the compliance timeline depicted in 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 a TSMS if they utilize the TSMS option. The initial COI must be obtained within 4 years from the TSMS approval. 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.

17. Some new parts AED 140.435 Health and Safety Plan 140.500 Handheld VHF radio 140.715 Survival Craft 141.305 Life buoys 141.360 Visual Distress Signals 141.375 Line Throwing Appliance 141.385 Flammable Storage 142.225 Smoke alarms in berthing areas 142.335 Heat detectors in galley (new vessels) 142.340 Fireman’s outfit (>79 foot, oceans or coastwise, no fixed fire suppression) 142.345 Fire axe 142.350 Machinery and Electrical 143 Alarms 143.245 Pressure vessels (5ft 3 15psi) 143.300 Lighting 143.310 Pilothouse alerter system 143.325 Remote shutdowns 143.335 Generator requirements 143.340 Additional requirements for vessels that tow oil or hazmat in bulk 143.400 Construction and arrangement 144

18. Questions? LT Javier Lopez – 808 522-8264 ext. 359 MST1 Russ Strathern – 808 522-8264 ext. 235