07/17/2017 – Reposted from USCG Safety Alert

Editor’s note: The Office of Investigations and Analysis online Marine Safety Alert library is currently undergoing migration to a new server and is temporarily unavailable. Until the library is back on line, Maritime Commons will post the full text of all Marine Safety Alerts so that our readers continue to receive important safety information.

During two recent vessel inspections Coast Guard marine inspectors participated in and witnessed occasions where the testing and maintenance of a CO2 system resulted in serious safety threats that could have easily led to loss of lives. The incidents included an accidental release in the space where a sensor was being tested that nearly resulted in a fatality and another situation where CO2 came close to being released without warning into an occupied engine room space after errors were made during routine system maintenance. CO2 fire extinguishing systems present an inherent risk to the personnel involved with their inspection, testing, and maintenance. Over the years the Coast Guard has become aware of multiple events where these systems have inadvertently released or leaked and caused the deaths of shipboard personnel, technicians and inspection personnel. CO2 system inspection, testing, and maintenance require thoughtful planning and risk mitigation efforts to prevent such events from happening.

In the first instance, the vessel’s chief mate and a Coast Guard inspector were testing the fire detection system. The mate and inspector went to the vessel’s hydraulic equipment room and the mate stood on a spare parts box in order to apply a heat gun to the heat actuator. The CO2 subsequently discharged directly above their heads and filled the room. The mate was overcome by the CO2 release and had to be revived by CPR after being pulled out of the space unconscious.

The problem was that the mate directed the heat to a “heat actuator” and not a “heat temperature transmitter.” The photo of a heat temperature transmitterdifference between these components is substantial. The detector is connected by wires to the monitoring system on the bridge while the release actuator directly connects to its local CO2 system through tubing. The heat actuator when heated creates a slight pressure in the tubing immediately activating the pneumatic control head of the CO2 bottle, releasing CO2 into the space without delay or warning.

Crewmembers were unfamiliar with the vessel’s system and had not referred to the associated manuals. Thus, their testing of the system was conducted without an understanding of the impacts of their actions, placing them and the Coast Guard inspectors at of CO2 system heat actuator

In a second unrelated event, an inspection for certification involving four inspectors was taking place while technicians were working on the CO2 system. A Coast Guard inspector in the machinery space was told that CO2 technicians were going to release the CO2, which was not part of the planned inspection. He was informed that the system became accidently primed for release when the pilot system was activated by a technician in training. As the technician was reconnecting the cable actuated release levers attached to the tops of the bottles, the activation cables remained connected to the levers. When the bottles were moved later in the servicing process, the cable tension increased to the point where the levers were lifted resulting in the release of charged bottles against a closed valve which prevented immediate release into the space.

The technicians ultimately decided they needed to release the entire engine room CO2 system to remedy the situation. They communicated their intentions to the vessel’s engineers, who performed an accountability of all personnel in the space. However, their count was incorrect as they missed a Coast Guard inspector who was still in the engine room. Only after the inspector’s partner realized his associate was missing was another more thorough sweep of the engine room made and the missing inspector found. Even after clearing the engine room the situation remained hazardous as various personnel stood by in the engine control room while the gas was released. After realizing the magnitude of the CO2 being released, the personnel in the control room evacuated to the vessel’s main deck and no further entry was made into the engine room until the fire department ruled it safe for human occupancy.

As a result of inadequate accountability measures and hazard communications, the safety of crew members and a Coast Guard inspector was placed at risk.

The Coast Guard notes that both of these instances reflect a lack of knowledge and risk awareness by the persons involved. The Coast Guard strongly recommends that:

  • Only persons adequately trained and properly evaluated be permitted to participate in CO2 testing and maintenance procedures onboard vessels;
  • Every person involved must know and consider the resulting outcomes for each step of the testing procedure prior to it taking place; and
  • Risks associated with CO2 and other systems should never be underestimated. Risk prevention activities should always lean towards providing the greatest safety margins for those involved including 100% accountability of all personnel aboard the vessel prior to conducting an operational test of a system.

Coast Guard Navigation and Vessel Inspection Circular (NVIC) 09-00: Change 1, Carbon Dioxide Fire Extinguishing System Safety contains additional CO2 safety and inspection information.

This safety alert is provided for informational purposes only and does not relieve any domestic or international safety, operational, or material requirements. Developed by the Investigations Division of Marine Safety Unit Portland, Coast Guard District 13 Prevention Division and the Office of Investigations and Casualty Analysis. Questions may be sent to

The Coast Guard has previously released CO2 related safety alerts. Safety Alert 15-14 recommends conducting a comprehensive pre-test meeting and simulated step-by-step “walk-through” between involved parties prior to actual testing of complex or potentially confusing systems. Operational controls for those involved should be implemented to maximize safety and reduce risk. Additionally, the Coast Guard strongly reminds all maritime operators of the importance in performing regular vessel specific emergency drills and to ensure that all crewmembers have the proper knowledge, skills, and abilities to respond to any potential emergency.

Click here to read the full Safety Alert posted by the USCG.

SUBCHAPTER M: One Year and Counting

Sub M One Year Countdown
Sub M One Year Countdown

Today, we begin the one-year countdown to Subchapter M.  On July 20, 2018, towing vessels are required to be in full compliance with Subchapter M.

Have you taken the initial steps towards compliance with Subchapter M? Are you ready for Subchapter M? 

As a Coast Guard Approved Third Party Organization (TPO), TVIB has a comprehensive solution for those companies choosing the TSMS option. We have a geographically dispersed group of auditors and surveyors from the west coast to the east coast, the gulf and the inland river system. Our auditors and surveyors have been working in the brown water segment of the industry for many years right alongside you. They understand your business, operational parameters and are poised to offer the greatest flexibility in performing services to fit your schedule and needs.

If your company is AWO RCP certified we are an AWO-recognized Third Party Auditing Organization approved to conduct RCP Management and Vessel Audits. We have a clear solution developed for those companies to utilize their RCP Management Certification as a path to receive their TSMS Certificate, consistent with CG-CVC Policy Letter 17-02.  We believe we can expedite this process as the overwhelming majority of RCP audits completed were performed by TVIB Certified AWO-RCP Auditors. We stand on the competence of our auditors and do not see that a company that has had a successful RCP Management audit performed by a TVIB Certified AWO-RCP Auditor within the past 3 years would have to undergo additional audits of their shoreside operation or onboard their vessels that also have completed a successful RCP Vessel Audit within the past 3 years.

For those companies that are not participating in the AWO RCP we have a documented process for a TSMS gap analysis, audit of the TSMS and vessel assessments and/or audits in order for a company to obtain their TSMS Certificate.

Companies choosing the TSMS option must operate under a TSMS Certificate at least 6 months before obtaining a COI for any of the vessels covered by the TSMS certificate.

Do your vessels have a valid Towing Vessel Bridging Program UTV decal? CG-CVC Policy Letter 17-01 allows you to utilize a valid UTV decal to receive full credit for an initial inspection for certification. This means that those vessels can be issued a COI without an additional visit from a Coast Guard inspector. Plan to update those decals if any have expired, they are good for 3 years.

Are you planning to have an internal or external survey program?  Maybe you’ve considered a hybrid approach of annual internal surveys with the five-year drydock/ISE performed by an external surveyor as a “check” on the system.  TVIB has developed a Model Internal Survey program that a company can modify and tailor to their specific needs.

We are expanding our staff and our Houston operation to address the increasing administrative responsibilities of our TPO activities.  We are working with developers on a software solution to manage all aspects of our oversight responsibilities.  Presently we are completing the phase one implementation strategy and will be rolling this out to our TPO customers, auditors and surveyors in the coming days.  We are building this solution to warehouse your TSMS, audit and survey reports, and track events. The system will provide alerts and reminders for upcoming events. TPO customers will have a portal built specifically for their organization.


For More Information Contact:

Tava S. Foret, Executive Vice President, Operations

Chris Parsonage, President

USCG: NVIC 01-16 CH-1 Use of Electronic Charts and Publications in Lieu of Paper Charts, Maps and Publications

July 18, 2017

Excerpt from the Federal Register Notice posted today:

SUMMARY: The Coast Guard (USCG) is announcing, the availability of Navigation and Vessel Inspection Circular (NVIC) 01–16 change 1. The NVIC provides that display of certain electronic charts and publications will meet—as an equivalency—the ‘‘marine charts,’’ ‘‘charts,’’ ‘‘maps,’’ or ‘‘publications’’ carriage requirements and provides for an equivalency for position fixing and plotting. USCG intends, by this policy, to provide a path for U.S. flagged vessels to replace paper charts and most hard copy publications if so desired.

FOR FURTHER INFORMATION CONTACT: Please address questions or feedback concerning this policy to LCDR Matthew Walter, telephone 202–372–1565 or email

Click here to download NCV 01-16 Change 1 – July 10, 2017

Click here to view the Federal Register Notice