TVIB News Ken Lamph

USCG: REVISIONS to NVIC 01-89 Change 1 Underwater Survey Guidance – UWILD Considerations

Review of the Updated UWILD Policy

The updated UWILD policy has no direct impact on the brown water fleet. It emphasizes the importance of visibility during underwater surveys conducted by divers or remotely operated vehicles (ROVs).

Brown water operations—typically conducted in inland and coastal waterways such as rivers, canals, and bays—often involve confined waters and limited visibility. These conditions make it difficult to meet the policy’s visibility requirements, which state:

  • Water clarity must be sufficient for the diver or ROV to view the full height of the propeller and rudder in a single frame.

If this level of clarity cannot be achieved, operators must consider alternatives such as relocating the vessel, waiting for improved conditions, or drydocking.

Other key updates:

  • Expanded Eligibility:Vessels over 15 years old may qualify for UWILD with certain conditions and CG-CVC endorsement.
  • Third-Party Oversight:Unclassed ITVs operating under a TSMS can use their TPO to verify UWILDs without mandatory Coast Guard presence. Simplified documentation applies, and both the TPO and OCMI must be notified.
  • Harmonization:DD/ISE dates may now align with Load Line (LL) inspections for unclassed vessels.
  • Technology Use:ROVs equipped with advanced cameras and lighting may improve visibility in marginal conditions.

All other UWILD policy requirements remain unchanged.

USCG: New CG-2692 Form – When and Why to Report a Marine Casualty: A Quick Guide for Towing Vessel Operators

With the recent update to the U.S. Coast Guard’s CG-2692 form (scroll down for download links)—Report of Marine Casualty, Commercial Diving Casualty, or OCS-Related Casualty—towing vessel operators must understand the difference between reporting a marine casualty and submitting this form. Timely notification and documentation are key to regulatory compliance and safety.

When to Report a Marine Casualty

You must immediately notify the nearest Coast Guard Sector Office (after addressing any safety concerns) when your vessel is involved in any of the following events—even if you are unsure whether it meets the threshold of a reportable marine casualty:

  • Any fall overboard, injury, or loss of life
  • An unintended grounding or unintended allision with a bridge
  • Flooding, collision, explosion, or fire
  • Loss or reduction of propulsion, steering, or electrical power
  • Any condition that adversely affects the vessel’s seaworthiness or fitness for route/service
  • Actual or potential environmental harm (e.g., oil spill)

Refer to Navigation and Vessel Inspection Circular (NVIC) 01-15, “Reporting Marine Casualties,” for additional guidance on the types of events that constitute reportable marine casualties and examples that clarify borderline situations.

📄 When to Submit CG-2692 Forms

A CG-2692 form is submitted only after a Qualified Investigating Officer (IO) (NVIC 01-15) determines that the occurrence is a reportable marine casualty under 46 CFR Part 4. In many cases, your initial verbal or electronic report to the Coast Guard will trigger that evaluation.

Submit CG-2692 if:

  • The Coast Guard has confirmed the incident is a reportable marine casualty
  • The event qualifies as a Serious Marine Incident (SMI):
    • A death or serious injury
    • Property damage in excess of $200,000
    • Discharge of oil or hazardous materials
  • Your tow (barge) sustains or causes damage
  • Chemical testing is required – Form CG-2692B must accompany the main CG-2692

Note: You are still required to notify the Coast Guard immediately, even if you are not yet certain whether an incident is reportable. NVIC 01-15 includes helpful examples that clarify the Coast Guard’s interpretation of “immediate” notification and what constitutes a reportable event.

Reporting & Submission Timeline

  • Report to the Coast Guard immediately after ensuring safety
  • If determined reportable, submit CG-2692 within 5 days of the incident

📝 Check Your TSMS for Company-Specific Reporting

If operating under a Towing Safety Management System (TSMS) for Subchapter M compliance, your TSMS may include additional internal requirements such as:

  • Internal notification procedures
  • Company-specific reporting timelines
  • Documentation and follow-up expectations

Review your TSMS regularly to ensure alignment with both Coast Guard and internal expectations.

⚠️ Why This Matters

Accurate and timely reporting enables the Coast Guard to:

  • Investigate incidents
  • Enforce safety regulations
  • Prevent future casualties

Failure to comply can lead to enforcement action, including fines or suspension of operations.

🔑 Key Takeaway

Know the difference between notifying the Coast Guard and submitting a CG-2692. Always review NVIC 01-15 and your company’s TSMS for detailed reporting expectations. Clear communication and proper documentation protect your crew, your vessel, and your company.

📎 Download Links

TVIB FAQ – Fuel Shutoff Testing

Fuel Shutoffs on Towing Vessels
We’ve published a new FAQ on our website to clarify how fuel shutoff valves should be tested. This resource covers testing expectations, frequency options, and Towing Safety Management System (TSMS) requirements.

Why Are Fuel Oil Valves Important?
Fuel shutoff valves are critical safety components designed to stop fuel flow to the engine during a malfunction or hazard. Regular testing ensures they work as intended, reducing the risk of fuel-related incidents.

Find Detailed Guidance in Our FAQ
For comprehensive answers and guidance on testing procedures and TSMS requirements, visit the FAQ section on our website: TVIB FAQ. Use the search function with the term “fuel shutoff” or navigate to 46 CFR Part 143 for relevant details.