TVIB News News and Updates

MSU Paducah and MSU Huntington Issue Their First COIs to Crounse Corporation

The inland towing industry’s brownwater fleet is ready for Subchapter M: Crounse Corporation receives COIs when MSU Paducah and MSU Huntington issue their first COIs

On June 27th, Crounse’s vessel the M/V Eva Kelley, was the first vessel in their fleet to receive their Certificate of Inspection (COI). Dylan Hesley, Manager of Safety, along with the shoreside team and the crew of the M/V Eva Kelley worked with MSU Paducah in submitting the required information for the COI application and getting the vessel ready for the inspection. Civilian Marine Inspector Joseph Brown said, “It is definitely a process to gather all of the required information needed for objective evidence but with constant communication between the vessel rep and the Coast Guard it can be relatively painless.” He went on to encourage companies to begin conversations with their local USCG Marine Inspectors and submit their vessel particulars as soon as possible. Submitting these details up front allows the local unit to build the vessel profile in the Coast Guard’s Marine Information for Safety and Law Enforcement (MISLE) system and move on to the step of reviewing objective evidence. Mr. Brown noted that reviewing the objective evidence takes considerable time on their part. TVIB recommends contacting each unit where a company will apply for a COI to determine their specific requirements as the USCG has not adopted a single standard. This was the first COI issued by Marine Safety Unit Paducah.

On July 13th, the M/V City of Maysville was the second Crounse vessel to receive a COI.  Mike Kidd, Port Captain, worked with the vessel’s crew and MSU Huntington to obtain the vessel’s COI. U.S. Coast Guard Commander Paul Mangini had this to say “The Coast Guard appreciates the dedication, diligence and willingness of the Crounse Corporation to put the effort in to achieve compliance with Subchapter M and supply the necessary information in order to generate the first Certificate of Inspection for the City of Maysville in the Port of Huntington/Tri-State zone.  We look forward to continued cooperation as we both work together to bring the rest of their towing vessel fleet into inspected status.” This was the first COI issued by Marine Safety Unit Huntington.

The term “uninspected towing vessel” was a misnomer placed on over 6,000 towing vessels as a way to classify them. Uninspected towing vessels, or UTVs, have been the most inspected uninspected vessels out there.  This term created a most-unearned negative connotation for the majority of the vessels as many in the inland towing industry have been participating in a third-party audited safety management system under the American Waterways Operators’ Responsible Carrier Program since the early 1990’s. Crounse Corporation is one of those companies.

What you’re seeing here is a true partnership between industry and the U.S. Coast Guard working together, to achieve a successful implementation and launch of Subchapter M. Crounse Corporation is clearly on the leading end of Subchapter M compliance. TVIB worked with Robbie Englert, Senior Vice President of Operations, along with a strong shoreside team for Crounse to be the first company to be issued a TSMS Certificate by TVIB.  The Crounse team is among our earliest and most ardent supporters. TVIB’s model is one that is shaped by the desire to raise the level of knowledge, understanding, and overall compliance with the programs for which we provide services. TVIB believes that the quality of our auditors and surveyors are the backbone of our organization. Although the phrase “a rising tide lifts all boats” is said to be a reference to economy often attributed to JFK, we believe it is quite fitting for how we think. At TVIB, we believe that when we increase the knowledge and understanding this improves the industry as a whole. We are here to be a solution and to ultimately bring about a safer maritime industry for all.

Congratulations to the crews of the M/V Eva Kelly and the M/V City of Maysville and the entire team at Crounse Corporation. Job Well Done!

TVIB THE TPO YOU KNOW AND TRUST

USCG: Is your Automated Identification System ready for Subchapter M?

Reposted from the Coast Guard Maritime Commons

7/3/2018: Is your Automated Identification System ready for Subchapter M?

Posted by LT Amy Midgett, Tuesday, July 3, 2018

Submitted by Lt.j.g. David Turay, Coast Guard Navigation Center

A vessel’s Automatic Identification System (AIS) is crucial to the crew’s safety. AIS is a situational awareness tool that was originally intended for collision avoidance, but it has many other applications:

  • SAR – Aids first responders in reaching vessels in distress.
  • Vessel Traffic Service (VTS) – AIS is used by surveilled VTS systems to provide additional navigation safety in busy ports and waterways.
  • Fleet Monitoring/Tracking – AIS is a cost effective way for operators to monitor their fleet activities.
  • Accident Investigations – Historical AIS data is important to thorough accident investigations, which identify ways to further improve maritime safety.

AIS broadcast is autonomous and continuously exchanges real-time safety and navigation information between AIS equipped vessels within VHF range of each other. Recognizing the critical role AIS has on our nation’s maritime safety and security, the Coast Guard developed the Nationwide AIS (NAIS), which consists of an expansive network of shore-based VHF towers that receive AIS transmissions from vessels transiting U.S. waterways.

AIS Data

AIS data falls into three categories: Static, Dynamic, and Voyage-related Data.

Static Data is information that must be programmed into the AIS at installation and is verified periodically. Static Data includes: Maritime Mobile Service Identity (MMSI); vessel type; vessel name; call sign (if assigned); IMO or Official Documentation Number (if assigned); and antenna location (which is also used to provide vessel dimensions).

Dynamic Data, such as position, course, speed, heading, and rate of turn is autonomously acquired from external or internal sensors (i.e. GPS, speed log, heading device or gyro). Dynamic Data is continuously broadcast every few seconds. Proper installation and operation of all sensors is critical to the proper operation of AIS and the accuracy of the information it exchanges.

Voyage-related Data (i.e. Navigation status, static draft, destination, and estimated time of arrival) is manually entered and should always be kept up to date. Navigation status must be updated throughout the course of a voyage. Vessels underway broadcast every 2-10 seconds, whereas vessels that are moored or at anchor broadcast every 3 minutes. Moored vessels that use an underway navigation status consume significantly more NAIS bandwidth. Bandwidth and throughput are crucial factors that may affect the response times of first responders that use NAIS information. Vessels should use the correct navigation status to remain compliant with federal regulations and to ensure NAIS performs at optimal levels.

Subchapter M and AIS

During the month of June 2018, over 50 percent of towing vessels operating in U.S. waters transmitted incorrect AIS data, and an alarming number of these vessels did not accurately report their dimensions or broadcast a properly assigned MMSI number. Failure to accurately report a vessel’s dimension significantly increases the risk of collision, especially in congested waterways or during low visibility conditions. Knowing the location of the bow in addition to the overall length of the vessel and associated barges is crucial to help approaching vessels react and maneuver appropriately. This is especially important when visibility is limited.

Subchapter M regulations bring numerous new requirements to the towing community. Vessel operators will be required to adhere to these new regulations in addition to the existing regulation for all AIS users, the AIS Carriage Requirement found in 33 CFR 164.46d(2). It requires vessel AIS to be maintained in effective operating conditions, which includes the broadcast of a properly assigned MMSI and all other AIS data fields.

AIS is a valuable navigation safety radio communication tool. However, its effectiveness is undermined by the broadcast of inaccurate, improper or outdated data. The deliberate broadcast of inaccurate AIS data may subject violators to monetary penalties by the Coast Guard, and operators may also be subject to significant penalties by the FCC for each violation of improper or inaccurate MMSI broadcast. Fortunately, the AIS carriage requirement is one of the easiest regulations to meet before scheduling vessel inspections.

Guidance and Verification

To assist AIS users, the Coast Guard has promulgated a two-page AIS Encoding Guide. The Navigation Center is also the home of the Vessel Information Verification Service (VIVS), a web-based self-help tool that allows users to check their vessel’s AIS data. VIVS search results will highlight any suspected AIS static data discrepancies. Towing vessel operators can then use this information to make any necessary corrections before scheduling vessel inspections.

Click here for the original post on Maritime Commons.

July Training Opportunities – Space Is Limited

TVIB and ACTSafe Training are hosting a Subchapter M suite of courses in Houston the week of June 9th – Space is Limited.  You can register for all three courses or just the one(s) needed.  Each course builds upon the other.  If you’ve already taken the MILA course consider expanding your depth of knowledge and exposure to critical Subchapter M elements. See below for course descriptions and links for registration.

Marine Internal Lead Auditor (MILA) – July 9-10 – Houston, TX – Marine Internal Lead Auditor

TVIB has partnered with ACTSafe Training in this Coast Guard recognized Marine Internal Lead Auditor course, designed to teach the specific skills and knowledge necessary to conduct and lead internal audits for commercial marine companies.

The course meets the requirements of ANSI Z 490.1 Criteria for Accepted Practices in Safety, Health and Environmental Training and the requirements of 46 CFR 138.310(d)(2).

Course Information and Registration


Risk Management – July 11 – Houston, TX

The RCP requires risk a risk process and most companies are not providing training in how to conduct risk assessments. This course is written by the author of the RCP risk section (Rick Dunn). Persons taking this class will leave with simple risk tools that can be used in the workplace. With Subchapter M becoming law in 2018, it makes sense to ensure your risk process meets the ISO 31000 risk standard.

You will learn:

  • Risk management vs Risk Assessment
  • The Risk Pyramid
  • RCP, TMSA3, Sub M risk requirements
  • Review key risk tools and concepts of ISO 31000
  • Failure Effects Mode Analysis (FEMA) risk methodology
  • How to use risk tools to assist in creating a Permit to Proceed Process for COI discrepancies under Subchapter M
  • How to conduct hazard bases qualitative risk assessments (format provided)
  • How to implement a simple yet effective JSA process

This course is suitable for managers, safety personnel, vetting advisors (oil majors and operators), regulators, operations managers and Port Captains.

Course Information and Registration


Subchapter M TSMS Objectices for Designated Persons – July 12 – Houston, TX

As the industry enters into a “regulated management system” world, the TSMS becomes critical to managers and those serving as Designated Persons under RCP or the ISM Code. This course is designed to help management and individuals protect their interests while demonstrating they are meeting the TSMS objectives of Subchapter M. The current language in Sub M appears to expose management and DPAs should a major incident occur or if a third party challenges their TSMS methodology. This course explores how best to protect your interests while making the TSMS more effective.

You will learn:

  • The history of the DPA with a case study review
  • Understanding how to meet the purpose of a TSMS for USCG and Customer needs
  • Critical success factors for marine managers and operations personnel
  • Management of Change concepts
  • Importance of Hierarchy of Controls in a TSMS improvement process
  • Each TSMS objective in Sub M is reviewed and methods to demonstrate how to meet them are discussed and explained
  • How to improve your internal audits to demonstrate compliance with the objectives
  • How to use Management Reviews to maximize compliance and improve effectiveness
  • Details of how the best operators ensure that their TSMS meets the objectives and is effective

This course is suitable for managers, DPA’s, safety personnel, vetting advisors (oil majors and operators), regulators, operations managers and Port Captains.

Course Information and Registration