Towing Vessel Inspection

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Darren Hill
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1 1 I n l a n d R i v e r s a n d G u l f C o a s t Section 8

2 Navigation Safety Panel Discussion 2 Moderator Coast Guard Perspective Industry Perspective Tava Foret LT Edward Ayoub MST1 Bryan Vitrano Tava Foret Tom McWhorter

3 Coast Guard Perspective 3 L T A Y O U B - U N I N S P E C T E D V E S S E L S D I V I S I O N, M S U P O R T A R T H U R M S T 1 V I T R A N O, U N I N S P E C T E D V E S S E L S D I V I S I O N, S E C T O R H O U S T O N - G A L V E S T O N

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5 The Good 5

6 The Bad 6

The Ugly 7 0300 September 23, 1993 47 DEAD Caused by Towing Vessel s Pilot becoming disoriented in

7 The Ugly September 23, DEAD Caused by Towing Vessel s Pilot becoming disoriented in heavy fog and striking bridge. Deadliest accident in Amtrak s history Big Bayou Canot Bridge, Mobile, AL

8 American Waterway Operators 1994 Established its own voluntary Responsible Carrier Program Operations incl. fuel transfer procedures Safety Training Environmental policy Incident Reporting Emergency Response and Equipment 8

9 American Waterway Operators 1998 Made Responsible Carrier Program mandatory for its members. Must undergo 3 rd party audits By 2000 all members had been audited (10% every 3 years) 13 companies left the organization rather than face the audit. 9

10 Maritime Transportation Act of

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12 Summer 2009 Phase 1 Began 108 Dedicated Billets New UTV Examiners are qualified/knowledgeable and build industry partnerships. Establishment of an NCOE Funding for Training Industry Initiated Exams (IIE) Decal Issuance 12

13 A Phased Approach 13 Summer 2009 Phase 1 Outreach & Education IIEs Testing of Risk Tool Qualification/PQS Id of FOFRs 01JUL12 Phase 2 Prioritized Exams Course Development Comments on NPRM 100% FOFRs examined Subchapter M Published Phase 3 COI Issuance Formal Training

14 Phase II 14 Began 01JUL12 Phase II wasn t supposed to start until ALL Districts were ready Port State Information exchange (PSIX) was supposed to be enabled Industry Initiated Exams to continue in Phase II and to take priority

15 Targeting Matrix 15

16 MSU Port Arthur Approx. 65 UTVs 16 20% 14% 66% Decaled Issued Decal Not Issued Unexamined* *0 vessels in operation left to be examined.

17 Future of MSU PA UTVs Continue Phase II efforts Ramification of SIRE Inspections Decal Renewals 17

Total FOR = 509 18 Sector H/G = 329 MSU Port

18 Total FOR = Sector H/G = 329 MSU Port Arthur = 65 MSU Lake Charles = 79 MSU Texas City = 36

19 Compliance Issues After more than 6300 uninspected towing vessel exams, some key issues have surfaced. 19

20 Current Compliance Issues Fuel Shut-Off Valves required by 46 CFR Location Marking Operation General Alarms required by 46 CFR Marking Supplemental flashing red light Navigation Lights required by 46 CFR Technical standards Approved type 20

21 Current Compliance Issues 21 Drug & Alcohol Testing/Records - 46 CFR 4.06 & 16 Testing devices - expiration date/improper stowage Record keeping - random testing EAP Program - display and distribution of training materials Recordkeeping 47 CFR 80 & 33 CFR Radiotelephone logs maintenance and entries Record of test and inspections before getting underway

22 Current Compliance Issues Magnetic Compass/Swing Meter - 33 CFR Not fitted or functioning Wrong equipment for area of operation Not properly illuminated Fire Detection Equipment - 46 CFR Panel inoperable Panel not properly labeled Proof of PE certification Marine Sanitation Devices - 33 CFR Not properly labeled Not properly secured against overboard discharge Inadequate supplies for proper operation 22

23 Current Compliance Issues Vessel Markings - 46 CFR Official Number not in accordance with requirements Official Number not permanently fixed Fire Extinguisher Brackets - 46 CFR Not approved type Pressure Vessels ******* Missing data plates Improper PV valves Nonstandard Improper repairs 23 Note: Not currently regulated on UTV s but my be classified as a Hazardous Condition

24 Towing Vessel National Center of Expertise TOWING VESSEL NATIONAL CENTER OF EXPERTISE OFFICE: (270) (X-203) FAX: (270) Web Address

25 Industry Perspective 25

26 Bureau 26 What one segment of the Towing Vessel industry is doing to prepare for s under 46 CFR Subchapter M

27 The Future of Auditing 27 Following the evolution of the TSAC Subchapter M process that began in 2004 that included: the review of 2 sets of draft language, the publishing of the NPRM in August of 2011, and the public hearings, It appeared there was an area of Subchapter M that needed more attention

28 More Work To Be Done There were several issues to consider: Would there be enough qualified auditors for Sub M? How would they be trained? What would happen if there were 20 different accepted organizations, each using different methods for conducting audits and each and submitting different audit reports? Could the Industry and Coast Guard reasonably expect consistency in auditing? With inevitable inconsistency could there be long-term acceptance of Sub M? What would be the fallout? 28 Who would suffer most from any push back?

29 A Solution 29 Formation of TVIB as a Professional Trade Organization for Marine Auditors and Surveyors to: Review credentials, experience and work history Develop a common audit tool for management and vessel audits Provide Training on the Regulatory Standard Set Member Standards and Guidelines Advocate on behalf of the Auditor Member

30 What Is TVIB? Non-profit organization formed in 2010 Filed for 501(c)(6) in 2013 Two Member Categories: Auditor Membership 30 Supporting Organization Membership Member-owned and governed Organization was turned over to the membership in May of 2013 and is now governed by the 21-member Board of Directors and an Executive Director

31 Purpose, Goals and Objectives 31 Train and certify members to conduct audits and inspections Perform the training and accreditation function for the American Waterways Operators Responsible Carrier Program (RCP). Pending the Final Rule Conduct training and accreditation function for auditors/surveyors working for USCG accepted organizations providing third-party audits and/or surveys under Subchapter M

32 The AWO Responsible Carrier Program 32 Early Fall of 1993 External and Internal Factors April 1994 Development of the RCP April 1998 January 1, % of the AWO Carrier Members were in compliance SIDE NOTE 2004 Subchapter M began 2008 the board voted to get out of the auditor accreditation business and later reaffirmed that decision TVIB entered into a 10-year agreement to assume the RCP Auditor Accreditation and Training Function from AWO

33 AWO-TVIB Agreement Overview 33 TVIB will provide the following in connection with the RCP: Certification of Auditors Conduct initial and recertification training Address auditor questions concerning the RCP TVIB will not directly oversee auditor s performance of audits Provide Continuing Education to the Auditors Develop and administer procedures for appeals and grievances Develop and enforce a substantive Code of Ethics Utilize an internal quality system based on an ANSI/Amer. Society of Quality Control Q or equivalent and attain ISO certification

34 AWO and TVIB Today and Tomorrow 34 Enhanced Management Checklist and Worksheet TVIB-Certified AWO RCP Auditor Course COMPLETED - August 6-8, Houston, TX November 5-7, Nashville, TN March 2014 Location TBN TVIB Upcoming Meetings November 2013 Board Meeting - Nashville, TN March 2014 Annual Members Meeting/Board Meeting Location TBN Enhanced Vessel Checklist(s) and Worksheet(s) 3-day Internal Auditor Course Evaluate the Development of an Electronic Audit Tool

Committee Structure 35 Auditor Accreditation and Oversight Committee Auditor Certification Verifies Credentials Evaluates Qualifications Issues Final TVIB Credential Auditor Training Prepares and

35 Committee Structure 35 Auditor Accreditation and Oversight Committee Auditor Certification Verifies Credentials Evaluates Qualifications Issues Final TVIB Credential Auditor Training Prepares and conducts Initial and refresher training Subcommittees Auditor Resources Committee Audit Process Develop and continuously improve the audit process Audit Checklist Develop and continuously improve the audit checklist/tool Auditor Oversight and Quality Control Evaluates Auditors Addresses Auditor Complaints Continuing Education Keep Auditor Pool up to date on changes to the audit process and audit checklist Provide other continuing education opportunities to the Auditors

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37 Navigation Safety Panel Discussion 37 Moderator Coast Guard Perspective Industry Perspective Tava Foret LT Edward Ayoub MST1 Bryan Vitrano Tava Foret Tom McWhorter

38 Coming up next: Western Rivers 38 Section 8

Subchapter M Information Session

Subchapter M Information Session AWO Summer Regional Meetings August 2016 The Big Picture Milestone in industry safety journey Raises regulatory floor industry-wide A new approach to Coast Guard inspection