Bulwark/handrail height has become a hot-button issue with the USCG during COI inspections, at least in one OCMI zone within D8. District 8 and the Office of Commercial Vessel Compliance (CVC) have upheld the Marine Inspector’s finding on every appeal. Some customers have even been denied the vessel’s COI as a result of this finding. As a result, we reached out to D8 Towing Vessel Coordinator, Jill Bessetti, and obtained the following information.
At issue is a vessel’s bulwarks and/or handrails being less than the OSHA recommended height of 39.5”- 40”. In an appeal determination letter, D8 Chief of Prevention stated the minimum height that would provide equivalent protection would be 30” from the deck. If non-compliant bulwarks/handrails are found on the vessel, the Marine Inspector should issue a CG-835v and should mark the deficiency as a work list item, meaning it would not be visible in PSIX. The company would then submit their proposal for bringing the vessel into compliance. According to District 8, no COI should be held up as a result of this deficiency. In instances where space or the vessel’s operations make installing compliant bulwarks/handrails not feasible, hand grabs would be accepted as an acceptable alternative.