TVIB News Subchapter M Updates

May 31, 2019 – CG – Engineering issued a new policy letter. Following are some excerpts from that letter that are specific to Subchapter M towing vessels under 65 feet long. Please click on the link below to download the full policy letter.

(1) Purpose.This policy letter provides guidance on the acceptance of fixed fire pump size requirements for towing vessels 65 ft or less to provide a level of safety that is equivalent to the requirements of reference (a) and (b), uninspected and inspected towing vessels, respectively. 

(3) Discussion. When developing references (c) and (d), the Coast Guard assumed smaller vessels would utilize portable fire pumps, while larger vessels would utilize fixed fire pumps; therefore, vessel size was not associated with fire pump requirements. This assumption imposed a larger burden on smaller vessels that opted to install fixed fire pumps. Generally, the fixed pump is required to have a higher capacity to accommodate the greater hydraulic losses expected from the extensive fire main systems used in larger vessels. In small vessels, however, the hydraulic losses of the smaller fire main systems are negligible, and the fixed fire pump need be of no higher capacity than the portable pump. Thus, in small vessels, fixed and portable pumps of similar capacity will provide similar fire streams affording an equivalent level of safety. Accordingly, for towing vessels 65 ft or less, the Coast Guard has determined a fixed pump that meets the portable pump capacity and pressure requirements meets an equivalent level of performance to the requirements in references (a) and (b). 

(4) Action.

b.   Subchapter M: For towing vessels 65 ft or less subject to 46 CFR 142.325, vessels may use a fixed pump that meets the performance requirements of 46 CFR 142.325(e)(1), instead of 46 CFR 142.325(a)(1). These towing vessels must also meet the requirements in 46 CFR 142.325 (a)(2), (b)-(d). 

Click here to download CG-ENG Policy Letter 01-19 Equivalency Determination – Fire Pumps for Subchapter C and Subchapter M Towing Vessels

May 9, 2019 – the USCG sent out the following notice via the GovDelivery

This is a reminder of a key 46 CFR Subchapter M implementation milestone that is quickly approaching. On or before July 22, 2019, owners and managing operators of Subchapter M towing vessels must implement a Health and Safety Plan (HSP) and the associated recordkeeping procedures regardless of whether or not the vessel has been issued a Certificate of Inspection (COI). Requirements include general health and safety procedures, identification and mitigation of health and safety hazards, and health and safety training for crewmembers and non-crewmembers.

Towing vessels operating under a Safety Management System (SMS) may already have the elements of the HSP covered within the SMS. For towing vessels that have not incorporated the HSP elements into their SMS, and for towing vessels utilizing the Coast Guard Inspection Option, the HSP would likely be a stand-alone document.

There is no requirement to submit the HSP to the Coast Guard or TPO for approval; however, the plan is subject to review during inspections and audits. Minimum health and safety requirements can be found in 46 CFR Part 140 Subpart E.

For more Coast Guard news, visit their online newsroom here.

Reposted from the Maritime Commons

Posted by LT Amy Midgett, Thursday, May 9, 2019

The Towing Safety Advisory Committee (TSAC) held its spring public meeting in Miami, Florida, March 13, 2019. Attendees represented the Coast Guard, the towing and barge industry, engineers, pilots/masters, port authorities, terminal operators, offshore operators, and the public.

After welcoming remarks from Rear Adm. John Nadeau, assistant commandant for prevention policy, the committee deliberated on current tasks, discussed new business, and received public comments.

Highlights from the meeting included:

• Capt. Janet Espino-Young from the 7th District Prevention office discussed the importance of industry partnerships and cooperation in implementation of inspections and recovery efforts after natural disasters.

• A subcommittee recommendation to establish three new workgroups to address 1) hull and stability for inland towing vessels; 2) consistency and clarification of Subchapter M topics; and 3) boundary separations and the impact on offshore/near coastal manning.

• A final report on Task No. 16-03, “Recommendations Regarding Operational Risks Associated with Towing LNG Barges.” Recommendations include how to identify and safely execute a critical tow and familiarization training for tug crews.

• A progress report on Task No. 17-02, “Load Line Exemption Review for River Barges on Lakes Erie and Ontario.” The subcommittee intends to complete an analysis of the ports of refuge named by the petitioner to determine if they will limit the size of the tow for the intended route.

• A presentation by Mr. Erik Johnson from the Office of Commercial Vessel Compliance at Coast Guard Headquarters on the number of new Certificates of Inspection against the goal of 25 percent of the Subchapter M population.

• A presentation from Ms. Melanee Libby regarding the Coast Guard’s 2018 Authorization Act and a new National Towing Safety Advisory Committee that will serve the same function as TSAC. Under the Act, TSAC is permitted to continue operating until Dec. 4, 2020.

The committee also heard public comments on various topics such as Subchapter M implementation for non-traditional tug and barge operations; clarification of types and limits of towing credentials; and a proposal to incorporate frequently asked questions and guidance into Subchapter M.

Copies of the meeting agenda and draft final reports are available on the TSAC Homeport webpage.

Click here to link to the full post from the Maritime Commons.