TVIB News Archives: FAQs

From Paper to Digital: NVIC 01-16 CH-3 – Chart & Publication Carriage Equivalencies for Inland Towing Vessels

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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.

What are the signage requirements for a CO2 fixed fire-extinguishing system?

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Fixed fire-extinguishing carriage requirements are discussed in 46 CFR 142.315, but one must step through a few other citations to identify the signage requirements for a CO2 fixed fire-extinguishing system.

The term “Fixed fire-extinguishing system” is defined in §136.110 which includes a carbon dioxide system meeting requirements of 46 CFR subpart 76.15 and 46 CFR 78.47-9 and 78.47-11.  These citations are where you find the signage requirements.

Controls [§76.15-10(h)]

Complete, but simple operating instructions to be posted at or near all pull boxes, stop valves, and cylinder storage room.

System Schematic Diagram [§76.15-10(h)]

If cylinder storage is not within the space to be protected, the controls instructions must include a schematic diagram of the system and instructions detailing alternate methods of discharging the system should the manual release or stop valve controls fail to operate.

Control Valve to Branch Lines [§76.15-10(h)]

Each must be marked to indicate the related space served.

Carbon Dioxide Alarms [§78.47-9]

Each alarm must be conspicuously marked: “WHEN ALARM SOUNDS VACATE AT ONCE. CARBON DIOXIDE OR CLEAN AGENT BEING RELEASED.”.

Spaces Storing CO2 Cylinders [§78.47-11(a)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. VENTILATE THE AREA BEFORE ENTERING. A HIGH CONCENTRATION CAN OCCUR IN THIS AREA AND CAN CAUSE SUFFOCATION.”.

Spaces Protected by CO2 [§78.47-11(b)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. WHEN ALARM OPERATES OR WINTERGREEN SCENT IS DETECTED, DO NOT ENTER UNTIL VENTILATED. LOCK OUT SYSTEM WHEN SERVICING.”.  *

Spaces Into Which CO2 Might Migrate [§78.47-11(c)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. DISCHARGE INTO NEARBY SPACE CAN COLLECT HERE. WHEN ALARM OPERATES OR WINTERGREEN SCENT IS DETECTED VACATE IMMEDIATELY.”.  *

* Wintergreen Scent Note [§76.15-60]

Each carbon dioxide extinguishing system installed or altered after July 2013, must have an approved odorizing unit to produce the scent of wintergreen, the detection of which will serve as an indication that carbon dioxide gas is present in a protected area and any other area into which the carbon dioxide may migrate.  “Altered” means modified or refurbished beyond the maintenance required by the manufacturer’s design, installation, operation and maintenance manual.  If the system does not include wintergreen odorizing unit, the reference to wintergreen scent may be omitted from signage.

General Alarm Requirements – Subchapter M

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General alarm requirements for towing vessels subject to Subchapter M are found in 46 CFR 143.235.  This FAQ is specific to the location of audible alarms, supplemental flashing red lights, and signage.

The regulatory text in §143.235(b)(2) requires that the general alarm must be:

“… capable of notifying persons in any accommodation, work space, and engine room”.

Additionally, §143.235(b)(2) requires:

“… in the engine room and any other area where background noise makes a general alarm hard to hear, a supplemental flashing red light…” along with the specified signage.

Audible Alarm Location

There is no regulatory requirement for the audible alarm to be installed in any specific physical location.  The requirement is that it must be audible in “any accommodation, work space, and the engine room.”

This leads to the importance of knowing what are considered accommodation and work spaces.  In short, these are spaces designed for people or areas where crew may be while on duty.  The specific Subchapter M definition of Accommodation Space and Work Space can be referenced at §136.110.

Supplemental Flashing Red Light

The supplemental flashing red light (supplemental light) must be installed:

  • In the engine room (at least one light is always required there).
  • In any other area where background noise makes a general alarm hard to hear.

Occasionally, auditors, surveyors, and vessel operators have differing opinions about which areas have background noise at a level that makes the general alarm difficult to hear.  When evaluating those other areas, if the audible alarm can be heard over any background noise, then a supplemental light is not required.

Keep in mind, ability to hear may vary, particularly if an individual has reduced hearing ability due to injury, aging, etc.  Although, each space/area must be individually evaluated by the operating company, generator rooms, steering rooms, tool rooms, shaft alley, etc. are common locations where supplemental lights are needed.

The supplemental light needs to be positioned so that it effectively alerts anyone in the area when the general alarm is activated.  Be aware that factors such as beams, bulkheads, insulation, dull paint and obstructions can reduce the light’s visibility.

Signage Requirements

Finally, be sure to post a sign at each supplemental light identifying its purpose. The required wording is:

“Attention General Alarm – When Alarm Sounds or Flashes Go to Your Station.”