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9/10/2013
Towing Vessel Inspection
I n l a n d R i v e r s a n d G u l f C o a s t – 2 0 1 3
Section 8 Towing Vessel Inspection
Navigation Safety Panel Discussion
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Moderator Tava Foret
Coast Guard Perspective LT Edward Ayoub MST1 Bryan Vitrano
Industry Perspective Tava Foret Tom McWhorter
Towing Vessel Inspection
L T A Y O U B - U N I N S P E C T E D V E S S E L S D I V I S I O N , M S U P O R T A R T H U R
M S T 1 V I T R A N O , U N I N S P E C T E D V E S S E L S D I V I S I O N , S E C T O R H O U S T O N - G A L V E S T O N
Coast Guard Perspective 3
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The Ugly
0300 September 23,
1993
47 DEAD
Caused by Towing Vessel’s Pilot becoming disoriented in heavy fog and striking bridge. Deadliest accident in Amtrak’s history – Big Bayou Canot Bridge, Mobile, AL
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Towing Vessel Inspection
American Waterway Operators
1994 – Established its own voluntary “Responsible Carrier Program” Operations incl. fuel transfer procedures
Safety Training
Environmental policy
Incident Reporting
Emergency Response and Equipment
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Towing Vessel Inspection
American Waterway Operators
1998 – Made “Responsible Carrier Program” mandatory for its members. Must undergo 3rd party audits
By 2000 all members had been audited (10% every 3 years)
13 companies left the organization rather than face the audit.
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Towing Vessel Inspection
Summer 2009 Phase 1 Began
108 Dedicated Billets – New UTV Examiners are qualified/knowledgeable and build industry partnerships.
Establishment of an NCOE
Funding for Training
Industry Initiated Exams (IIE)
Decal Issuance
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Towing Vessel Inspection
A Phased Approach…
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Phase 1 Outreach & Education IIEs Testing of Risk Tool Qualification/PQS Id of FOFRs
Phase 2 Prioritized Exams Course Development Comments on NPRM 100% FOFRs examined
Phase 3 COI Issuance Formal Training
Summer 2009
Subchapter “M” Published 01JUL12
Towing Vessel Inspection
Phase II
• Began 01JUL12
• Phase II wasn’t supposed to start until ALL Districts were ready
• Port State Information eXchange (PSIX) was supposed to be enabled
• Industry Initiated Exams to continue in Phase II and to take priority
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66%
20%
14%
Decaled Issued
Decal Not Issued
Unexamined*
*0 vessels in operation
left to be examined.
MSU Port Arthur Approx. 65 UTVs
Towing Vessel Inspection
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Future of MSU PA UTVs
Continue Phase II efforts
Ramification of SIRE Inspections Decal Renewals
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Towing Vessel Inspection
Total FOR = 509
Sector H/G = 329
MSU Texas City = 36
MSU Port Arthur = 65
MSU Lake Charles = 79
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Compliance Issues
After more than 6300 uninspected towing vessel exams, some key issues have surfaced.
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Current Compliance Issues
• Fuel Shut-Off Valves required by 46 CFR 27.203
• Location
• Marking
• Operation
• General Alarms required by 46 CFR 27.201
• Marking
• Supplemental flashing red light
• Navigation Lights required by 46 CFR 25.10-3
• Technical standards
• Approved type
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Current Compliance Issues
• Drug & Alcohol Testing/Records - 46 CFR 4.06 & 16
• Testing devices - expiration date/improper stowage
• Record keeping - random testing
• EAP Program - display and distribution of training materials
• Recordkeeping – 47 CFR 80 & 33 CFR 164.80
• Radiotelephone logs maintenance and entries
• Record of test and inspections before getting underway
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Current Compliance Issues
• Magnetic Compass/Swing Meter - 33 CFR 164.72 • Not fitted or functioning
• Wrong equipment for area of operation
• Not properly illuminated
• Fire Detection Equipment - 46 CFR 27.203 • Panel inoperable
• Panel not properly labeled
• Proof of PE certification
• Marine Sanitation Devices - 33 CFR 159.7 • Not properly labeled
• Not properly secured against overboard discharge
• Inadequate supplies for proper operation
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Current Compliance Issues
• Vessel Markings - 46 CFR 67.121
• Official Number not in accordance with requirements • Official Number not permanently fixed
• Fire Extinguisher Brackets - 46 CFR 162.028-3
• Not approved type
• Pressure Vessels *******
• Missing data plates • Improper PV valves • Nonstandard • Improper repairs
• Note: Not currently regulated on UTV’s but my be classified as a Hazardous Condition
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Towing Vessel National Center of Expertise
TOWING VESSEL NATIONAL CENTER OF EXPERTISE
OFFICE: (270) 444-7715 (X-203)
FAX: (270) 444-8094
Web Address – WWW.USCG.MIL/TNVCOE
Towing Vessel Inspection Bureau
What one segment of the Towing Vessel industry is doing to prepare for Towing Vessel Inspections under 46 CFR Subchapter M
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The Future of Auditing
Following the evolution of the TSAC Subchapter M process that began in 2004 that included: the review of 2 sets of draft language,
the publishing of the NPRM in August of 2011,
and the public hearings,
It appeared there was an area of Subchapter M that needed more attention
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More Work To Be Done
There were several issues to consider: Would there be enough qualified auditors for Sub M?
How would they be trained?
What would happen if there were 20 different accepted organizations, each using different methods for conducting audits and each and submitting different audit reports?
Could the Industry and Coast Guard reasonably expect consistency in auditing?
With inevitable inconsistency could there be long-term acceptance of Sub M?
What would be the fallout?
Who would suffer most from any push back?
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A Solution
Formation of TVIB as a Professional Trade Organization for Marine Auditors and Surveyors to: Review credentials, experience and work history
Develop a common audit tool for management and vessel audits
Provide Training on the Regulatory Standard
Set Member Standards and Guidelines
Advocate on behalf of the Auditor Member
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What Is TVIB?
Non-profit organization formed in 2010
Filed for 501(c)(6) in 2013
Two Member Categories: Auditor Membership
Supporting Organization Membership
Member-owned and governed
Organization was turned over to the membership in May of 2013 and is now governed by the 21-member Board of Directors and an Executive Director
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Purpose, Goals and Objectives
Train and certify members to conduct audits and inspections
Perform the training and accreditation function for the American Waterways Operators Responsible Carrier Program (RCP).
Pending the Final Rule – Conduct training and accreditation function for auditors/surveyors working for USCG accepted organizations providing third-party audits and/or surveys under Subchapter M
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The AWO Responsible Carrier Program®
Early Fall of 1993 – External and Internal Factors
April 1994 – Development of the RCP
April 1998
January 1, 2001 – 100% of the AWO Carrier Members were in compliance
SIDE NOTE – 2004 Subchapter M began
2008 – the board voted to get out of the auditor accreditation business and later reaffirmed that decision
2013 - TVIB entered into a 10-year agreement to assume the RCP Auditor Accreditation and Training Function from AWO
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AWO-TVIB Agreement Overview
TVIB will provide the following in connection with the RCP:
Certification of Auditors
Conduct initial and recertification training
Address auditor questions concerning the RCP
TVIB will not directly oversee auditor’s performance of audits
Provide Continuing Education to the Auditors
Develop and administer procedures for appeals and grievances
Develop and enforce a substantive Code of Ethics
Utilize an internal quality system based on an ANSI/Amer. Society of Quality Control Q9001-2000 or equivalent and attain ISO certification
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AWO and TVIB – Today and Tomorrow
Enhanced Management Checklist and Worksheet
TVIB-Certified AWO RCP Auditor Course COMPLETED - August 6-8, 2013 - Houston, TX
November 5-7, 2013 - Nashville, TN
March 2014 – Location TBN
TVIB Upcoming Meetings November 2013 – Board Meeting - Nashville, TN
March 2014 – Annual Members Meeting/Board Meeting – Location TBN
Enhanced Vessel Checklist(s) and Worksheet(s)
3-day Internal Auditor Course
Evaluate the Development of an Electronic Audit Tool
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Committee Structure
Auditor Accreditation and Oversight
Committee
Auditor Resources
Committee
Auditor Certification
•Verifies Credentials
•Evaluates Qualifications
•Issues Final TVIB Credential
Auditor Training
•Prepares and conducts Initial and
refresher training
Auditor Oversight and Quality
Control
•Evaluates Auditors
•Addresses Auditor Complaints
Audit Process
•Develop and continuously improve
the audit process
Audit Checklist
•Develop and continuously improve
the audit checklist/tool
Continuing Education
•Keep Auditor Pool up to date on
changes to the audit process and
audit checklist
•Provide other continuing education
opportunities to the Auditors
Subcommittees
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Navigation Safety Panel Discussion
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9/10/2013
Moderator Tava Foret
Coast Guard Perspective LT Edward Ayoub MST1 Bryan Vitrano
Industry Perspective Tava Foret Tom McWhorter