TVIB News FAQ Category: 46 CFR Part 143 – Machinery and Electrical Systems and Equipment

What are my options for reviewing the fuel shutoffs required under §143.260 during an annual survey?

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PREFERRED:  Company to identify testing frequency within TSMS. During the annual survey the surveyor visually inspects system components and has a crew member perform a function test with the vessel safely secured at a dock, fleet, or mooring.

ALTERNATIVE:  During annual survey the surveyor visually inspects system components.  If vessel is underway and not able to secure at a dock, fleet, or mooring, a function test WILL NOT be performed.  If documentation can be provided showing fuel shutoff valves have been tested as indicated in the TSMS, the surveyor can accept this as objective evidence of successful function testing.  If there is no documentation of testing IAW the companies TSMS the surveyor will issue a finding that successful function testing was not able to be performed due to operating conditions and that there was no current documentation of testing as required by the TSMS. The anticipated corrective action plan from the vessel operator would be to have system function tested within 30 days and documentation of same provided to TVIB as objective evidence.

In either case, if the visual inspection of the Fuel Shutoff valves reveals a deficient condition, a finding will be issued and may affect the vessel’s ability to operate until a successful function test is completed to the satisfaction of the attending surveyor.

IN ALL CASES:  A non-operational Fuel shutoff valve is a major non-conformity, which requires notification to TVIB within 24 hours (real-time is preferred).

NOTE: A valve is a device not a system. The operation of the valve does not act to suppress the fire. §142.240(a) specifically references “machinery shutdowns”, which requires testing every 12 months. TSMS testing frequency should identify testing frequency IAW either of the below associated references:

ASSOCIATED REFERENCES:

  • §142.240 (a): All portable fire extinguishers, semi-portable fire-extinguishing systems, fire-detection systems, and fixed fire-extinguishing systems, including ventilation, machinery shutdowns, and fixed fire-extinguishing system pressure-operated dampers on board the vessel, must be inspected or tested at least once every 12 months, or more frequently if otherwise required by the TSMS applicable to the vessel.
  • Table 46 CFR 143.245 (b): identifies “All other essential systems” as having a testing frequency of at least once every 3 months.
  • §136.110 includes systems for suppression of fire as an essential system.

Required Inspections – Electric Water Heaters

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QUESTION: What inspections are required for an electric water heater on a towing vessel?

RESPONSE:  To answer this question, first you must identify some characteristics of the electric water heater.

46 CFR 136.110 defines a pressure vessel as “… a closed tank or cylinder containing gas, vapor, or liquid, or a combination thereof, under pressure greater than atmospheric pressure.”

An electric water heater is a closed tank that contains liquid and is under pressure greater than atmospheric pressure.

The following italicized text contains excerpts from the regulatory citations and not the language in its entirety.

§ 143.300 further defines requirements for pressure vessels as those that are greater than or equal to 37.4 gallons and over 15 pounds per square inch.  Under this set of requirements, there are some that are applicable to an electric water heater:

 (a) be equipped with a spring loaded relief valve that prevents pressure from exceeding the MAWP by more than 10 percent.

 (b) be externally examined annually and relief valve tested in accordance with § 143.245 (i.e., twice every 5 years with no more than 3 years between testing)

 (c) be marked with MAWP

 (d) if installed after July 20, 2018, must meet ABS rules (see § 143.540)

Since the water heater will operate at the pressure of the potable water system, the gauge requirement of § 143.300(a) is more commonly applied by having a pressure gauge on the output side of the potable water pump or thereafter in the piping system.

While not applicable to Subchapter M vessels, one can look at Subchapter T (46 CFR 182.320) and Subchapter K (§ 119.320) for similar regulatory guidance. Those regulations put specifications that apply to a water heater that is UL listed, under 120 gallons, and heat input is less than 200,000 BTU per hour.

Additionally, the water heater manufacturer likely provides documentation to guide the owner on maintenance. A quick web search of some major water heater manufacturers identified that at least annually the temperature pressure relief valve should be tested, and one was found to call for the relief valve to be reinspected once every three years and replaced if necessary. The vessel owner/operator should consult the manufacturer’s documentation for the make/model installed on the vessel.

 

Generator Failure – Reportable Marine Casualty?

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QUESTION: I have a regulatory interpretation question regarding generators.

A generator fails on a vessel equipped with 3 generators while the other two generators are fully operable. Only one generator is needed to carry the load for the vessel.  Are we required to report this to the Coast Guard and TVIB?

RESPONSE:  Short answer is yes, based on the following:

Guidance concerning reportable marine casualties was taken from NVIC 01-15 title 46, code of federal regulations (CFR), part 4 marine casualty reporting procedures guide with associated standard interpretations 46 CFR 4.05-1.

The loss of an online generator IS considered a reportable marine casualty no matter the duration. However, if you have the required 2 operational power supplies, you continue to meet the requirements under Subchapter M.

The benefit of this setup is that the vessel still has the required power supplies so you can schedule repairs to the affected generator later and continue operations without lost time.

Once reported, this may be handled differently from one Coast Guard unit to another since it does not affect operations. These would be the 2 most likely and agreed-upon options but they do not preclude an alternate path not discussed in this FAQ under the direction of the OCMI.

  • CG-835V not issued, Notify TPO IAW companies TSMS for repairs. Continue operations
  • CG-835V issued, Action Code A, Self-reported Worklist item, not fwd. facing. Notify TPO IAW Companies TSMS. Continue operations.