The USCG has informed of an increasing failure rate amongst the inspected towing vessel fleet with regards to fixed and portable emergency dewatering equipment failing to operate as designed.
Emergency dewatering equipment, whether fixed or portable, is essential vessel equipment placed on vessels to maintain the safe operation, survivability, and safety of personnel during emergencies that may require its use.
In the Marine Safety Alert 02-21, USCG Inspections and Compliance Directorate said they have found the fixed emergency dewatering system failing to operate due to loss of prime.
Proper testing of the dewatering equipment should include ensuring the pump has the ability to physically take suction and that it can produce a sufficient discharge stream. This test can be conducted without discharging over the side into the water,
…USCG said.
It is reminded that emergency dewatering equipment is defined as an essential system in Subchapter “M”. In accordance with 46 Code of Federal Regulations (CFR) 143.25(a), essential systems must be regularly tested and examined. These tests and examinations must verify that the systems function as designed and that the procedures used for such testing are in accordance with the manufacturer’s instructions or the Towing Safety Management System (TSMS) applicable to the vessel. In the case of emergency dewatering equipment, it must be tested at least every three months as shown in 46 CFR Table 143.245(b).
Recommendations
The USCG strongly recommends that towing vessel owners, operators, and third-party organizations conduct the following actions to ensure that crews understand how to use the emergency dewatering equipment and that it operates when needed in an emergency situation:
- Ensure that operational tests are conducted at the appropriate intervals to confirm proper functionality.
- Ensure the dewatering system has the ability to take suction and has an adequate discharge.
- Ensure the system is intact to include all check valves/foot valves and operates as designed.
- Instruct all crewmembers on the proper operation of emergency dewatering equipment, whether fixed or portable.
- Engage with TPOs to ensure they are conducting operational tests as required.
- Incorporate the policy and procedures for testing and maintenance of emergency dewatering equipment into the vessel’s TSMS.
