TVIB News FAQ Category: 46 CFR Part 140 – Operations

Can towing vessels use electronic charts instead of paper charts? 

Yes. Under 46 CFR 140.705 and NVIC 01-16 CH-3, towing vessels may carry electronic navigational charts (ENCs) displayed on a compliant Electronic Chart System (ECS) in lieu of official paper charts.

– Inside the Boundary Line (inland waters): RTCM Class B ECS is acceptable, but you must also carry a backup (either a second Class B ECS or ENC-derived paper charts).
– Seaward of the Boundary Line (offshore): RTCM Class A ECS or ECDIS is required; Class B ECS is only acceptable as an optional backup.
– The ECS must receive position data from a type-approved electronic position-fixing device (EPFD) such as GPS.

Operator Takeaway: If your towing vessels operate inland, you can switch to electronic charts, but you must maintain redundancy (backup ECS or ENC-derived paper).

What counts as an acceptable backup for electronic charts?

Two options are allowed:
1. Secondary Class B ECS (separate unit capable of displaying ENC data).
2. ENC-derived printed paper charts, provided they meet NVIC criteria.

Technical Detail: ENC-derived paper charts must be:
– Produced by NOAA, USACE, NGA, a river authority, or a foreign government.
– Printed at a large enough scale for safe navigation.
– Printed within 6 months of the intended voyage or manually corrected to the latest updates.
– Printed on durable, water-resistant paper suitable for navigation plotting.

Operator Takeaway: If you don’t want to maintain two ECS units, you must keep ENC-derived charts current and on board.

Are ENC-derived paper charts acceptable instead of NOAA paper charts?

Yes. Since NOAA has ended traditional lithographic paper chart production, ENC-derived paper charts are recognized as an equivalent.

– Must comply with NOAA’s Technical Memorandum NOS CS 60 on best practices.
– Must be printed on suitable media (stable, tear-resistant, erasable with pencil, water-resistant).
– Still subject to the 6-month freshness rule.

Operator Takeaway: If you prefer paper for backup or primary use, you must print your own ENC-derived charts and manage update/printing intervals.

Can towing vessels keep required publications in electronic form?

Yes. Required carriage publications under 33 CFR and 46 CFR can be electronic if they are the latest version reasonably available and accessible on board.

– Must be accessible offline (without internet):
– Navigation Rules (USCG)
– Vessel Traffic Service (VTS) Rules (USCG)
– Can be accessible online (with internet):
– Coast Guard Light List
– Local Notices to Mariners
– U.S. Coast Pilot® (NOAA)
– NOAA Tide & Current Tables
– NGA Sailing Directions, List of Lights, Notice to Mariners
– USACE Navigation Notices
– River Authority Current Tables

Operator Takeaway: You can go paperless for most publications, but you must have offline access to Navigation Rules and VTS rules. A laptop or tablet with local files satisfies this.

What will be checked during audits, surveys, and Coast Guard inspections?

During compliance checks, the following items will be reviewed under Enclosure (2) of NVIC 01-16 CH-3:

– ECS type approval or manufacturer’s declaration of conformity must match NVIC Table 1 requirements.
– ENC data must be current (latest edition and updates).
– ECS display must show chart source, edition, and update information.
– ECS display size must meet minimums (e.g., Class B requires 7.8” x 7.8”).
– Vessel’s actual position must match the ECS position display.
– Crew must demonstrate familiarity with ECS functions (waypoint plotting, route planning, scaling).
– ENC-derived paper charts must be printed or corrected within 6 months.
– Electronic publications must be accessible (offline vs. online) and reflect the latest versions available.

Operator Takeaway: Crews should expect auditors, surveyors, and Coast Guard personnel to verify both equipment compliance and operator competence with ECS and publication management.

Does this NVIC apply to international voyages?

No. NVIC 01-16 CH-3 applies only to domestic U.S. requirements under 33 CFR and 46 CFR. It does not alter obligations under the International Convention for the Safety of Life at Sea (SOLAS).

Operator Takeaway: If your towing vessels operate internationally or are subject to SOLAS certification, you must maintain SOLAS-compliant chart and publication carriage regardless of these equivalencies.

Does this NVIC impose new legal requirements?

No. NVICs are guidance documents, not regulations. Operators may continue using official paper charts and publications until CFRs are amended.

Operator Takeaway: This NVIC provides options and flexibility — you can adopt electronic/ENC-derived solutions now, or continue with traditional paper until you’re ready to transition.

 

QUESTION: Are potable water tanks required to have protection such as a screen on the vents for safety or to prevent bugs from getting in?

RESPONSE: Yes. Vent screens are one of the measures that might be used to prevent contamination of potable water.

46 CFR 140.510(b) – As far as practicable, the owner or managing operator must implement other types of safety control measures before relying on Personal Protective Equipment. These controls may include administrative, engineering, source modification, substitution, process change or controls, isolation, ventilation, or other controls.

Further, the regulations also state:

21 CFR 1250.82(c) – Each potable water tank shall be provided with a means of drainage and, if it is equipped with a manhole, overflow, vent, or a device for measuring depth of water, provision shall be made to prevent entrance into the tank of any contaminating substance. No deck or sanitary drain or pipe carrying any nonpotable water or liquid shall be permitted to pass through the tank.