Prepared for Military Sealift Commandby Emprise Corporation
UNCLASSIFIED
2UNCLASSIFIED OPR: N7
• Objective - introduce participants to regulatory body expectations and preparations for upcoming inspections and surveys
• Enabling Objectives - understand and be able to describe the following:– Commercial shipping regulatory bodies, regulations, rules and
international conventions• Code of Federal Regulations (CFR) – https://www.ecfr.gov/• American Bureau of Shipping (ABS) - https://ww2.eagle.org/• International Maritime Organization (IMO) - http://www.imo.org/
– Differences between statutory regulations and classification rules– Accessing CFR, ABS Rules, and IMO conventions online– USCG and ABS inspection and survey procedures and check lists– USCG and ABS inspection and survey deficiencies– Accessing ABS survey reports and USCG vessel inspection reports
Learning Objectives
Presenter
Presentation Notes
THIS MODULE PROVIDES A BRIEF OVERVIEW OF IN-DEPTH TRAINING WILL BE PROVIDED IN ADDITIONAL TRAINING MODULES
COMMERCIAL SHIPPING REGULATIONS ARE DISCUSSED IN DETAIL IN OTHER COURSES MSC ships are voluntarily designed and built using commercial ship design standards Commercial standards include standards that are unique to the maritime industry (e.g., SOLAS, MARPOL, Load Lines, SIM, and STCW) Maritime industry standards invoke a variety of commercial standards that are shared with other industries (e.g., ISO, IEEE, NFPA, ASTM, ASME< ANSI Use of Navy design standards limited to military-unique mission requirements UNREP Ammunition handling and stowage Flight deck certification C4ISR (Command, Control, Computers, Communication, Intelligence, Surveillance, and Reconnaissance)
5UNCLASSIFIED OPR: N7
U.S. Coast Guard Inspection Timline
Inspection for Certification and Renewals – an inspection of the vessel’s structure, boilers, pressure vessels, piping, main and auxiliary machinery, electrical installations, lifesaving appliances, fire-detecting and extinguishing equipment, pilot boarding equipment, pollution prevention equipment is in satisfactory condition and fit for the service for which it is intendedAnnual Inspections - same as the inspection for certification but less in scope
Periodic Inspections - is the same scope as the Inspection for Certification
Dry Dock Exams - examination of all accessible parts of the vessel's underwater body and all through-hull fittings.Internal Structural Examinations (ISE) - examination of main strength members
Cargo Tank Internal Examination - examination of the internals of all cargo tanks
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE 33 CFR and 46 CFR ARE DISCUSSED IN DETAIL IN ANOTHER COURSE
6UNCLASSIFIED OPR: N7
Code of Federal Regulations
• 33 CFR and 46 CFR - govern the design, operation, and maintenance of U.S. commercial vessels
• Available online: https://www.ecfr.gov/cgi-bin/ECFR?page=browse
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE 33 CFR and 46 CFR ARE DISCUSSED IN DETAIL IN ANOTHER COURSE
• USCG Certificate of Inspection (COI) valid for five-years, with requirement for interim inspection at one-year anniversary of issuance
Presenter
Presentation Notes
CTRL + CLICK ON EACH IMAGE TO OPEN AND REVIEW CONTENT ONLINE USCG INSPECTIONS ARE DISCUSSED IN DETAIL IN ANOTHER COURSE Port State Information eXchange (PSIX) system Contains vessel specific information derived from the United States Coast Guard's Marine Information Safety and Law Enforcement System (MISLE) Information contained in PSIX represents a weekly snapshot of Freedom of Information Act (FOIA) data on U.S. flag vessels, foreign vessels operating in U.S. waters, and Coast Guard contacts with those vessels Information on unclosed cases or cases pending further action is considered privileged information and is precluded from the PSIX system Deficiencies are tracked to verify condition has been properly resolved, as well as serve as data for Coast Guard audits of Recognized Organizations’ operations Marine Safety Manual, Volume II: Materiel Inspection Outlines vessel inspection procedures Job Aids (CG-840 Inspection Books) Used by Marine Inspectors during the course of their inspections Vessel operators are also encouraged to use them in preparation for applicable Coast Guard inspections They are not a substitute for nor do they in any way alter regulatory requirements PDF files are intended to be printed using a duplex printer and double sided along the short edge. The document can then be assembled into a book
Defined – Flag State Action Codes“Code 30 – Ship Detained” is a technical or operational-related deficiency that individually or collectively indicate aserious failure, or lack of effectiveness, of theimplementation of the Safety Management System (SMS)which immediately impacts crew/passenger safety, hullseaworthiness, or the environment, and temporarycorrective action is not possible to meet less stringentrequirement initiating the
“Code 17 – Rectify deficiencies prior to departure” is usedfor a deficiency which must be rectified before the ship sailsbut is not serious enough to warrant a detention, or/andcan reasonably be rectified before the ship sails.
A “Self-Reported” box is also included on the new CG-835Vand allows a consideration to be given to a vessel owner oroperator on future risk based or targeted inspectionprograms. An owner or operator that has a strong safetyculture and has identified a substandard condition with anassociated corrective action receive credit for highlightingdeficiencies to the Marine Inspector.
Presenter
Presentation Notes
CTRL + CLICK ON CG-835V FORM IMAGE TO OPEN AND REVIEW CONTENT ONLINE Coast Guard Form CG-835V, Vessel Inspection Requirements is used to document deficiencies during inspections CG-835V was developed to support better data analytics and the development and monitoring of Key Performance Indicators (KPIs)
9UNCLASSIFIED OPR: N7
USCG Alternate Compliance Program
Presenter
Presentation Notes
CTRL + CLICK ON EACH IMAGE TO OPEN AND REVIEW CONTENT ONLINE ALTERNATE COMPLIANCE PROGRAM IS DISCUSSED IN DETAIL IN ANOTHER COURSE Alternate Compliance Program (ACP) - Recognized Organization’s (ABS) actions may be required to clear a Coast Guard identified deficiency
CTRL + CLICK ON EACH IMAGE TO OPEN AND REVIEW CONTENT ONLINE ALTERNATE COMPLIANCE PROGRAM IS DISCUSSED IN DETAIL IN ANOTHER COURSE Alternate Compliance Program (ACP) - Recognized Organization’s (ABS) actions may be required to clear a Coast Guard identified deficiency
• 46 CFR 1.03, Appeals From Decisions or Actions of an OCMI• Appeal must be submitted in writing and received by the appeal authority within
30 days after the decision or action being appealed• 46CFR Subpart 1.03 should be read carefully before submitting any appeal
package
Appeals From Decisionsor Actions of an OCMI
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE If you decide to appeal an OCMI decision, address the cover letter to the District Commander and submit the request package to the local unit or command with OCMI authority (e.g., Marine Safety Unit or Sector). OCMI will review and forward the request package with a cover memo to the District Commander for determination District Commander will review the request package and notify you of their decision with a letter If appeal was denied, you have the right to appeal the District Commander’s decision Respond to the denial letter indicating that you desire to appeal to the COMDT, which is the next and final authority Upon receipt of your letter indicating appeal to higher authority, the District Commander will forward the request package with a cover memo to the COMDT for final agency review and decision COMDT will notify you of the final agency decision with a letter
ABS SURVEYS ARE DISCUSSED IN DETAIL IN ANOTHER COURSE Annual surveys Must be completed within ± three months of annual class certificate issuance anniversary date Consist of: General inspection of hull, equipment and machinery Internal inspection of select tanks and major machinery (continuous survey) Witnessing of certain tests of ship’s equipment Intermediate surveys Must be conducted within 21-39 months of class certificate issuance Consist of: Examinations of structure Hull examinations generally supplemented by thickness measurements to help identify substantial corrosion, significant deformation, fractures, damages or other structural deterioration Bottom/docking survey Ultrasonic thickness measurements of hull Underwater inspection in lieu of drydocking (UWILD) may be considered for intermediate surveys External general inspection of hull Internal inspection of select tanks and major machinery (continuous survey) Boiler survey (as applicable) Surveys for the maintenance of class notations (as applicable) Witnessing of certain tests of ship’s equipment Class renewal surveys (special surveys) Conducted every five years for purpose of renewing class Consideration may be given in exceptional circumstances to granting extension for maximum period of three months after due date Consists of: Examinations of structure Hull examinations generally supplemented by thickness measurements to help identify substantial corrosion, significant deformation, fractures, damages or other structural deterioration Bottom/docking survey, including ultrasonic thickness measurements of hull Tailshaft survey Internal inspection of select tanks and major machinery (continuous survey) Boiler survey (as applicable) Surveys for the maintenance of class notations (as applicable) Witnessing of certain tests of ship’s equipment Continuous Surveys May be undertaken at request of ship owner Special survey requirements are carried out in regular rotation to complete all requirements within five-year period Notional arrangement provides for survey of approximately 20% of total number of survey items during each year of five-year period Each item surveyed becomes due again for survey approximately five years from date of last survey Annual survey will not be credited and Certificate of Classification will not be endorsed unless continuous survey items which are due or overdue at time of annual survey are either completed or granted an extension Bottom/Docking Surveys Must be examined twice in every five-year period with maximum of 36 months between consecutive surveys Examination of outside of ship's underwater hull and appendages One of the two surveys must be concurrent with special survey Carried out with ship either in dry dock or afloat (Underwater Inspection in Lieu of Drydocking (UWILD)) UWILD contingent upon: Type and age of ship Ship being outfitted for underwater inspection (e.g. underwater hull markings and sea chest blanks) No history of unusual underwater hull repairs No outstanding recommendations for repairs to propeller, rudder, stern frame, underwater structure, or sea valves Internal examination of representative tanks and cargo holds Acceptable prevailing water conditions (i.e., acceptable range of visibility) In event underwater inspection reveals damage or deterioration that requires further attention, Surveyor may require vessel be drydocked in order to undertake a detailed survey and necessary repairs Tailshaft Survey Tailshaft modified survey - examination that may be accepted at alternate five-year tailshaft surveys provided shaft arrangement is in accordance with specific requirements Tailshaft partial survey - allows for postponement of complete survey having a periodicity of 5 years for 2.5 years Survey of tailshafts and stern bearings Tailshaft complete survey Complete examination at periodicity based on type of shaft and its design “Complete” means shaft is drawn up for examination or that other equivalent means of examination are provided Boiler Surveys Boilers and thermal oil heaters surveyed twice in every five-year period Periodicity of boiler survey is normally every 2.5 years Steam boilers, superheaters and economizers examined internally and externally Where necessary, external surfaces are to be made accessible for inspection by removal of insulation and lining
13UNCLASSIFIED OPR: N7
American Bureau of Shipping RulesAvailable online: https://ww2.eagle.org/en.html
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE ABS RULES ARE DISCUSSED IN DETAIL IN ANOTHER COURSE ABS Rules & Guides are derived from generally accepted principles of naval architecture, marine engineering and related disciplines More than 200 Rules, Guides and Guidance Notes
• ABS Rules & Guides (325) – are the heart of our classification organization. ABS Rules & Guides are derived from principles of naval architecture, marine engineering and related disciplines.
• Available online: https://ww2.eagle.org/en/rules-and-resources/rules-and-guides.html
Note: Starting January 1, 2020, any new vessel that is covered by Marine Vessel Rules will need to meet the requirements laid out in the respective Rules.
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE 33 CFR and 46 CFR ARE DISCUSSED IN DETAIL IN ANOTHER COURSE
Note: Starting January 1, 2020, any new vessel that is covered by Marine Vessel Rules will need to meet the requirements laid out in the respective Rules.
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE 33 CFR and 46 CFR ARE DISCUSSED IN DETAIL IN ANOTHER COURSE
Note: Starting January 1, 2020, any new vessel that is covered by Marine Vessel Rules will need to meet the requirements laid out in the respective Rules.
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE 33 CFR and 46 CFR ARE DISCUSSED IN DETAIL IN ANOTHER COURSE
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE OPEN AND REVIEW LIST OF REQUIRED CLASSIFICATION AND STATUTORY SURVEYS ONLINE REVIEW SURVEY STATUS REPORT ONLINE�REVIEW SURVEY CHECKLISTS ONLINE ABS Eagle Survey Manager ABS database of vessel particulars and classification survey status
Statutory Surveys are required by law. They generally lead to the issue or endorsement of a statutory certificate. Class surveyors often carry out statutory surveys under the authority of the U.S. Coast Guard.
Classification Surveys are aimed at establishing that the ship sufficiently meets the conditions of class retainment, as well as to check the operation of mechanisms, devices and installations.
Presenter
Presentation Notes
STATUTORY REGULATIONS AND CLASSIFICATION RULES ARE DISCUSSED IN DETAIL IN OTHER COURSES 33 CFR and 46 CFR are developed an maintained by the U.S. Coast Guard IMO conventions are international treaties developed and maintained by IMO, that are adopted by signatory countries IMO conventions adopted by the U.S. are invoked in the Code of Federal Regulations by U.S. Coast Guard Statutory regulations Legally binding and enforceable Civil and/or criminal sanctions for violation Enforced by Flag State Authority U.S. Coast Guard is the U.S. Flag State Authority Enforcement of certain IMO conventions is delegated to ABS by USCG in connection with USCG Alternate Compliance Program Classification Rules Not legally binding Sanctions for violation are limited to suspension or revocation of classification Enacted and enforced by classification societies
20UNCLASSIFIED OPR: N7
Statutory Regulationsand Classification Rules
Classification RulesStatutory Surveys
• IMO Conventions• International Convention for the
Safety of Life at Sea (SOLAS)• Convention on International
Regulations for Preventing Collisions at Sea (COLREGS)
• International Convention on Load Lines (LL)
• International Convention for the Prevention of Pollution from Ships (MARPOL)
• International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW)
• International Safety Management (ISM) Code
• ABS Rules for Building and Classing Steel Vessels
• ABS Rules for Building and Classing Steel Vessels Under 90 Meters in Length
• ABS Guide for Building and Classing High Speed Naval Craft
Presenter
Presentation Notes
STATUTORY REGULATIONS AND CLASSIFICATION RULES ARE DISCUSSED IN DETAIL IN OTHER COURSES 33 CFR and 46 CFR are developed an maintained by the U.S. Coast Guard IMO conventions are international treaties developed and maintained by IMO, that are adopted by signatory countries IMO conventions adopted by the U.S. are invoked in the Code of Federal Regulations by U.S. Coast Guard Statutory regulations Legally binding and enforceable Civil and/or criminal sanctions for violation Enforced by Flag State Authority U.S. Coast Guard is the U.S. Flag State Authority Enforcement of certain IMO conventions is delegated to ABS by USCG in connection with USCG Alternate Compliance Program Classification Rules Not legally binding Sanctions for violation are limited to suspension or revocation of classification Enacted and enforced by classification societies
21UNCLASSIFIED OPR: N7
ABS Survey Deficiencies
Condition of Class
Statutory Condition
It is recommended that the striker plate and
bottom shell be repaired prior to completing the
Intermediate Hull Survey …
It is required the watertight door at 1-103-4 be restored to its original
configuration in compliance with Load Line requirements …
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE Outstanding Recommendations (OSR) - used to document deficiencies during surveys Synopsis of Deficiencies – examples of deficiencies noted during Port State Control Inspections of vessel documentation (certificates) Pre-Port Arrival Quick Reference and Downloadable Check List – checklist of documentation, equipment, and systems subject to Port State Control Inspections
22UNCLASSIFIED OPR: N7
American Bureau of Shipping Client Portal
Presenter
Presentation Notes
CTRL + CLICK ON IMAGE TO OPEN AND REVIEW CONTENT ONLINE ABS RULES ARE DISCUSSED IN DETAIL IN ANOTHER COURSE ABS Rules & Guides are derived from generally accepted principles of naval architecture, marine engineering and related disciplines More than 200 Rules, Guides and Guidance Notes
• During this module, we have discussed:– Commercial shipping regulatory bodies, regulations, rules and
international conventions• Code of Federal Regulations (CFR)• American Bureau of Shipping (ABS) BS Classification Rules• International Maritime Organization (IMO) conventions
– Differences between statutory regulations and classification rules
– Accessing CFR and ABS Rules online
– USCG and ABS inspection and survey procedures and check lists
– USCG and ABS inspection and survey deficiencies
– Accessing ABS survey reports and USCG vessel inspection reports
Summary
26UNCLASSIFIED OPR: N7
• For additional information, please refer to:– 33 CFR – Navigation and Navigable Waters– 46 CFR – Shipping– International Convention for the Safety of Life at Sea (SOLAS)– Convention on International Regulations for Preventing Collisions at Sea
(COLREGS)– International Convention on Load Lines (LL)– International Convention for the Prevention of Pollution from Ships
(MARPOL)– International Convention on Standards of Training, Certification and
Watchkeeping for Seafarers (STCW)– International Safety Management (ISM) Code– ABS Rules for Building and Classing Steel Vessels– ABS Rules for Building and Classing Steel Vessels Under 90 Meters in
Length– ABS Guide for Building and Classing High Speed Naval Craft– Port State Information eXchange (PSIX) system– Marine Safety Manual, Volume II: Materiel Inspection
Additional Information
Presenter
Presentation Notes
CONTINUED ON NEXT SLIDE
27UNCLASSIFIED OPR: N7
– Job Aids (CG-840 Inspection Books)– Procedures for Port State Control– Port State Control Examiner Job Aid– ABS Eagle Survey Manager– ABS Survey Status Reports– ABS Survey Check Lists– ABS Synopsis of Port State Control Inspection Deficiencies – ABS Pre-Port Arrival Quick Reference and Downloadable Check List
Additional Information
28UNCLASSIFIED OPR: N7
Date Version Description Author5/1/19 0.0 Draft presentation Mark Stoegbauer9/18/19 1.0 Revised title; Revised presentation
to reflect MSC template; Corrected slide ratio, formatting errors, redundancies, and errors; Updated various URL links and graphics
Gary Fields
1/8/2020 2.0 Revised ABS slides to reflect changes to the format of the ABS Client Portal
