Captain’s Corner: Inspection of Towing Vessels

U.S. Coast Guard photo of CAPT Tom Allan taken by Petty Officer 2nd Class Timothy TamargoMany of you have been closely monitoring the development of the Towing Vessel Regulations since 2004, and you have been patiently awaiting their implementation. So are we! March 2015 is now the forecasted period to publish the Final Rule but there is still a lot of work to do before we issue the first Certificate of Inspection. Much like the implementation of the Marine Transportation Safety Act, or any other significant Coast Guard action, you can expect a simultaneous release of a complementary implementation policy such as a Navigation and Vessel Inspection Circular (NVIC) to outline the pathways for the implementation of the regulations. To provide you a bit more detail on this subject, this Captain’s Corner is brought to you by Mr. Robert Butts, Chief of the Uninspected Vessel Branch who will be implementing this change for the Sector Jacksonville area of responsibility. As always, if you have recommendations for future topics we would appreciate your input. See you in the port!
– CAPT Tom Allan

Inspection of Towing Vessels

By Mr. Robert Butts, Chief of the Uninspected Vessel Branch

Many of you have been closely monitoring the development of the Towing Vessel Regulations since 2004, and you have been patiently awaiting their implementation. So are we! March 2015 is now the forecasted period to publish the Final Rule but there is still a lot of work to do before we issue the first Certificate of Inspection. Much like the implementation of the Marine Transportation Safety Act, or any other significant Coast Guard action, you can expect a simultaneous release of a complementary implementation policy such as a Navigation and Vessel Inspection Circular (NVIC) to outline the pathways for the implementation of the regulations. To provide you a bit more detail on this subject, this Captain’s Corner is brought to you by Mr. Robert Butts, Chief of the Uninspected Vessel Branch who will be implementing this change for the Sector Jacksonville area of responsibility. As always, if you have recommendations for future topics we would appreciate your input. See you in the port!
-CAPT Tom Allan.

The United States Coast Guard will implement the third and final phase of the Towing Vessel Bridging Program (TVBP) when we publish 46 Code of Federal Regulations (CFR), Subchapter M. The highly anticipated Inspection of Towing Vessels, Final Rule is predicted to be published in March 2015. Pursuant to the Coast Guard and Maritime Transportation Act of 2004, Public Law 108-293 of August 9, 2004, a significant regulatory project was undertaken that will transition the majority of the uninspected towing vessels, currently regulated under 46 CFR, Subchapter C into the category of vessels subject to inspection by the Coast Guard. To implement such a monumental endeavor, we developed the TVBP to increase meaningful interaction between the towing vessel industry and the Coast Guard. The TVBP promotes extensive industry outreach, the qualification of Coast Guard examiners to national standards, and the examination of each towing vessel’s compliance with existing regulations.

The proposed inspection regulations, 46 CFR Subpart M, are much more comprehensive than the existing regulations for uninspected towing vessels. For example, each vessel subject to the inspection regulations will need to outfitted, operated and managed to ensure compliance with the operation, lifesaving, fire protection, machinery and electrical systems, along with vessel construction standards. Although the Coast Guard inspection standards may sound daunting, many existing towing vessels in our Port are already in compliance with similar safety standards required by Classification Societies such as American Bureau of Shipping. In addition, vessels are carefully managed by responsible companies with sound safety management systems.

With the addition of towing vessels as a category of vessel subject to Coast Guard Inspection, our local domestic fleet of responsibility will double; and we may experience a significant increase in workload. It is still to be seen how much work will befall upon the Marine Inspectors as owners and operators of towing vessel will have two options to demonstrate compliance with Subchapter M. Compliance can be gained and continuously demonstrated by either implementing a Towing Safety Management System or by scheduling an inspection by a Coast Guard Marine Inspector. What is for certain is that the Coast Guard and the towing vessel industry is cooperatively working to promote safer work practices and reduce casualties on towing vessels.

Although Subchapter M is predicted to be published in March 2015, I invite you to routinely monitor the progress of the rule through the administrative process. The Unified Agenda can be found by searching on “1625-AB06”. Likewise, the Coast Guard established a Towing Vessel National Center of Expertise (TVNCOE) in Kentucky; and they offer a wealth of information and assistance. Visit the TVNCOE online. We continuously strive to develop new and foster existing partnerships, and the TVBP has certainly provided us that opportunity. We look forward to exercising those partnerships as we transition the uninspected towing vessel fleet into compliance with 46 CFR, Subchapter M. For more information, please contact LCDR Marc Montemerlo (904) 564-7653 or Mr. Robert Butts (904) 564-7664.

Featured image by JAXPORT on Flickr, CC

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