Subchapter M Inspection of Towing Vessels in the Mid-Atlantic

Transcription

1 Subchapter M Inspection of Towing Vessels in the Mid-Atlantic Virginia Maritime Association Towing Vessel and Barge Subcommittee Meeting Sep 14, 2016 Rear Admiral Meredith Austin

2 Overview Scene Setter Fifth District Overview Impact of Sub M on US Inspected Fleet Subchapter M Highlights Subchapter M Implementation Towing Safety Management Systems Benefits Questions Sub M or other

3 Scene Setter Today we re seeing significant increase in demand across all of our daily activities we are facing a convergence of risks that demand the Coast Guard s strategic action and commitment of resources. Admiral Paul F. Zukunft There has never been a greater demand for the Coast Guard

4 U.S. Fifth District Area of Responsibility 2,700 Personnel 4 Sectors 36 Stations 10 Patrol Boats 11 ATON Teams 5 Buoy Tenders 3 Construction Tenders 3 Harbor Tugs 2 Air Stations 5 Fixed Wing 14 Helicopters

5 Impact of Subchapter M Fifth Coast Guard District U.S. Flag Inspected Vessel Fleet of Responsibility 273 towing vessels (Sub M) 915 other vessels (Sub D, I, K, O, T, etc.) 1,188 total vessels Approximately 30% Increase in Size of Fifth District s Inspected Vessel Fleet of Responsibility

6 U.S. Towing Vessel Fleet- 5,841 Vessels Approximately 50% Increase in Size of Coast Guard s Inspected Vessel Fleet of Responsibility

7 Subchapter M Highlights Increases oversight of towing industry Expands safety and operational standards Introduces Safety and Health Plans Includes multiple compliance options Introduces Towing Safety Management Systems Certification of Third Party Organizations

8 Sub M Implementation YR 0 YR 1 & 2 YR 3 YR 4 YR 5 YR 6 YR 7-10 YR11 Effective Date of Final Rule Implement TSMS Prepare vessel etc. 25% Deferred Machinery & Electrical 5yrs fm COI 50% Deferred Machinery & Electrical 5yrs fm COI 75% Deferred Machinery & Electrical 5yrs fm COI 100% Deferred Machinery & Electrical 5yrs fm COI Full Compliance 20Jun16 20Jul16 20Jul17 20Jul18 22Jul19 20Jul20 19Jul21 19Jul22 Sub M effective but most of Parts delayed for 2 years or after COI is issued. WT & Wx tight stds apply. Keel laid date for new vessels Major conversion requires COI before re-entering service 25% of fleet must have COIs except companies w/ only 1 vessel All vessels must have Health and Safety Plan Requirements for COIs phased in over four years beginning 20Jul18 Parts implemented with exception of Health/Safety Plan, Pilothouse alerter system & towing machinery requirements.* TSMS certificates must be issued by TPOs six months prior to COI.. 50% of fleet must have COIs Companies w/only 1 vessel must have COI 75% of fleet must have COIs 100% of fleet must have COIs * 5 years after COI, existing vessels must comply with Pilothouse alerter system & towing machinery rqmts.

9 Sub M Implementation USCG - Strategy USCG - Lines of Effort Policy Development Establishment of Policy Council that meets twice a week; comprised of HQ, Areas and District reps. NVICs on TPO guide, compliance and implementation MSM Vol III manning published in Federal Register Inspector Training Development of job aids, surge training & C-School Industry Outreach Development/posting of Sub M inspection aids (i.e., TUGSAFE) Posting of FAQs: webpage w/existing FAQs and form to submit new Qs Towing Vessel Safety Advisory Committee (TSAC) Task Statement on Sub M Implementation and associated work groups. Sector industry days Goals Industry Prepared for Compliance Successful TPO Approvals Qualification of CG Inspectors Consistent Application of Regulations

10 Sub M Compliance Options Coast Guard Option - Traditional inspection; all inspections conducted by Coast Guard personnel. Towing Safety Management System (TSMS) Option Implementation of TSMS and use of Third Party Organization (TPO) to demonstrate and verify compliance.

11 TSMS Survey Programs External - Surveys are conducted by TPO, which can be a Classification Society. Internal - Surveys are conducted by trained personnel with a direct affiliation to the vessel, owner or managing operator. Internal surveys, or examinations, can be completed in stages over time. Combination - flexibility to use TPO or Class Society in lieu of internal company resources or contracted surveyors. (e.g., internal topsides and external drydockings).

12 TSMS Highlights Towing company (TC) develops and implements SMS and conducts annual internal audits. TPO issues TSMS Certificates, conducts management audits twice every 5 years, and vessel audits before initial COI and once every 5 years. TPO issues non-conformities and clears CG issued deficiencies. TPO documents compliance, submits required reports to CG and maintains records. Vessel surveys can be a continuous event scheduled over time (up to 1-year), and can be completed by TPO or TC depending on survey program chosen. Credit dry docks and ISEs can be continuous event scheduled over time, and can be completed by TPO, TC or contracted individual depending on survey program chosen. CG OCMI inspects vessel at initial COI and once every 5 years, and uses TSMS objective evidence to significantly reduce scope of inspection. CG OCMI approves vessel s route and manning. CG TVNCOE approves TPOs, TPO surveyors, maintains list of approved TPOs, audits TPOs, and notifies local OCMI of major non-conformities.

13 Benefits of a TSMS Flexibility Can be scaled for company size and type Flexibility to survey over 1 year rolling/continuous surveys No annual CG inspection - don t have to schedule days/weeks in advance & potentially take vessel out of service No CG attendance at drydock or ISE Significantly reduced CG time at COI issuance Permits to proceed addressed by TSMS Accountability Assigns responsibilities and authorities Continuous Compliance Uses process approach to continually assess, maintain and/or improve compliance Consistency Clear, well defined procedures and roles Documentation Provides information to management for better decision making and TSMS evaluation Management Review Checking & Corrective Action Implementation & Action Policy Planning

14 Questions and Comments