In late August, the US Coast Guard Towing Vessel National Center of Expertise published the latest updates to the Frequently Asked Questions regarding Subchapter M, inspected towing vessels.
FAQ 136-018 –Is a fleet boat exempt from Subchapter M? (updated)
This does not include the movement of barges carrying oil or hazardous material in bulk. All towing vessels, regardless of size, involved in the movement of barges carrying oil or hazardous material in bulk shall be certificated and manned in accordance with their COI. A fleet boat may be exempt from Subchapter M provided that the vessel is operating exclusively in a Limited Geographic Area as defined in 46 CFR §136.110 as determined by the local Captain of the Port (COTP), and that the vessel meets the excepted vessels provisions as coordinated with their local OCMI.
Part 137 -Vessel Compliance
FAQ 137-021 – What must occur prior to a TSMS vessel receiving its initial COI? (updated)
The process that must occur prior to issuance of an initial COI is as follows:
- 6 Months Before COI Inspection – If the TSMS and company are in compliance with Sub M requirements, the TPO approves the TSMS. The TPO conducts a management audit and issues a TSMS certificate to the company.
- Vessel Surveys and Audits – The company completes an internal vessel survey and an external vessel audit under the internal survey program. The TPO completes an external vessel survey and an external vessel audit under the external survey program.
- 3 Months Before COI Inspection – Company schedules initial COI with the OCMI.
- 30 Days Before COI Inspection – Company submits application for inspection to the OCMI, along with objective evidence as per §§136.210 and 137.202.
- Initial COI Inspection – The Coast Guard conducts the inspection and COI is issued.
* In some cases a decal will be accepted as the inspection for an initial COI.
§136.210 also discusses the process that an owner or managing operator must follow in order to schedule a COI inspection. In addition, the preamble to the regulation, page 40032, column 2, provides a short sequence of events for issuance of a COI.
Finally, in accordance with §138.315(b)(1), an external vessel audit is required 6 months prior to issuance of the initial COI, for vessels subject to an owner or managing operator’s TSMS that have been owned or operated for 6 or more months. For vessels subject to an owner or managing operator’s TSMS that have been owned or operated for fewer than 6 months, §138.315(b)(2) requires that an external audit must be conducted no later than 6 months after the issuance of the initial COI.
FAQ 137-023 -Will there be a standardized inspection form for drydock?
No. There will not be a standardized inspection form for drydock, but the Subchapter M job aid is under development and will include drydock references.
FAQ 137-027 -To what standard are we holding grandfathered doublers on the hull for inland river boats?
Referring to §144.200, an existing vessel may be deemed by the OCMI or TPO, to be in compliance with structural standards provided that the vessel is built, equipped, and maintained to conform to the rules of a recognized class society appropriate for the intended service and routes, but not classed. Existing vessels can also be deemed compliant if the vessel has been both in satisfactory service insofar as structural adequacy is concerned and does not cause the structure of the vessel to be questioned by either the OCMI, or TPO engaged to perform an audit or survey. See also FAQ 137-029 on guidelines to determine acceptable hull structure integrity and 137-032 on criteria to determine degree of wastage, pitting, and improper repairs.
FAQ 137-036 -How will the Coast Guard establish dates for hull examinations and internal structural examinations (ISEs) for vessels inspected under Subchapter M?
The hull exam and ISE dates will be based on the issuance date of the COI.
Part 139 – Third Party Organizations
FAQ 139-017 -Will CG recognize TVIB auditor certification for proof of experience vs. the Subchapter M reference of 2 management audits and 6 vessel audits in last 5 years?
It is not necessary for the Coast Guard to recognize the certification program of a TPO. It is the TPO’s responsibility to ensure they employ qualified auditors and surveyors in accordance with §139.130.
Part 140 – Operations
FAQ 140-025 –Are Coast Guard approved Bridge Resource Management courses required for master, mate, pilot credential holders under SubChapter M? (updated)
Yes, in accordance with Standards of Training, Certification, and Watchkeeping (STCW). There is no requirement under Subchapter M.
46 CFR 11.463 General requirements for national endorsements as master, mate (pilot), and apprentice mate (steersman) of towing vessels.
(f) Deck officers who serve on the following seagoing vessels must comply with the requirements of §11.309 (Requirements to qualify for an STCW endorsement as Officer in charge of a navigational watch (OICNW) of vessels of 500 GT or more (operational level)) and §11.311 (Requirements to qualify for an STCW endorsement as master of vessels of 500 GT or more and less than 3,000 GT (management level)) of this subpart for the appropriate STCW endorsement:
(1) A towing vessel on an oceans voyage operating beyond near-coastal waters.
(2) A towing vessel on an international voyage.
(3) A towing vessel of 200 GRT or more on a domestic, near-coastal voyage.
(g) Endorsements as mate (pilot) or master of towing vessels may be issued with a restriction to specific types of towing vessels and/or towing operations such as articulated tug barge (ATB) vessels that do not routinely perform all of the tasks identified in the Towing Officer Assessment Record (TOAR).
(h) Figure 11.463(h) illustrates the towing officer endorsement structure, including crossover points. The section numbers on the diagram refer to the specific requirements applicable.
46 CFR 11.321 Requirements to qualify for an STCW endorsement as officer in charge of a navigational watch (OICNW) of vessels of less than 500 GT limited to near-coastal waters (operational level).
(a) To qualify for an STCW endorsement as OICNW, an applicant must—
(3) Provide evidence of having satisfactorily completed approved training in the following subject areas:
(iv) Bridge resource management;
FAQ 140-050 -Vessels over 65’ are required to have a fog bell at least 11.8” in diameter. If the vessel’s PA is on a battery backup, will that suffice as a sound producer?
Yes, the PA system will suffice as a sound producer providing it has the same respective sound characteristics as a bell and manual sounding of the prescribed signals is always possible. In addition, the system must produce a sound pressure level of not less than 110 dB at 1 meter.
Part 142 -Fire Protection
FAQ 142-017 –Are existing Halon (or CO2 systems for that matter) acceptable on existing vessels “as is?” Is the Coast Guard going to require further assessment of agent volumes, piping, nozzles, placement of pressure switches, etc.? Subchapter M only discusses “fixed systems” but doesn’t direct operators to design or performance standards.
Existing vessels must comply with Subchapter M on July 20, 2018. 46 CFR 142.215(a) states that all fixed fire-extinguishing systems required by part 142 must be approved by the Commandant (CG-ENG). The definition of a “fixed fire-extinguishing system” can be found in 46 CFR 136.110, which also provides references for the design requirements of each system.
A fire-extinguishing system must have been approved by the Commandant at the time of installation and meet the design and installation standards required by regulations at the time of installation or new regulations if they are retroactive. Fire-extinguishing systems onboard an existing vessel need to meet the requirements referenced in 46 CFR 136.110. Halon systems or other extinguishing systems that are no longer approved by the Commandant will have to demonstrate that the system was approved at the time of installation.
Part 144 – Construction & Arrangement
FAQ 144-018 -With regard to stability, is the GICW (Gulf Intracoastal Waterway) considered “Protected” or “Partially Protected”?
Generally, the GICW waters are designated as protected waters. However, certain segments of the GICW are designated as partially protected waters by the cognizant OCMI because of the open water characteristics of portions of rivers, estuaries, harbors, lakes and similar areas. Check with the cognizant OCMI to identify partially protected waters in areas through which vessels plan to transit.
FAQ 144-021 -What are the different requirements for watertight and weathertight integrity by route?
The requirements contained in §144.320 are closely aligned with those stipulated for vessel operational safety contained in §140.610. Refer to the Notice of Final Rulemaking for more details. §140.610(c) requires the master to ensure that all hatches and openings of the hull and deck (i.e. closure devices, as referred to in §144.320(b)) are kept tightly closed except: (2) when operating on rivers with a tow, if the master determines the safety of the vessel is not compromised; or (3) when operating on lakes, bays, and sounds, without a tow during calm weather, and only if the master determines that the safety of the vessel is not compromised. It is with these provisions in mind that the last sentence of §144.320(b) refers to route: “These devices must be suitable for the intended route.”
While §140.610 does not apply to an existing towing vessel until July 20, 2018 or the date that vessel is issued a COI (§140.105), whichever is earlier, the requirements of §144.320 are intended to help mitigate the risk of uncontrolled water ingress and to facilitate run-off of water on deck.
If a vessel is assigned a load line, watertight and weathertight integrity requirements for the conditions of load line assignment would take precedence.
FAQ 144-022 -Is there a standard for gaging requirements?
For an existing vessel, minimum requirements for hull thickness measurements (a.k.a. “gagings”) should follow recommendations given in NVIC 7-68.
For a new vessel, 46 CFR 144.205(d) requires the structural standard selected to be applied throughout the vessel including maintenance, alteration, and repair. This requirement therefore extends to minimum requirements for thickness measurements (gagings) provided in the standard selected (e.g., for a new vessel that selected the ABS Under 90 meter Steel vessel rules, the gaging requirements in Part 7, Chapter 3, section 2/5.1.15(a) would apply). Deviations are subject to approval by the Marine Safety Center.
Find out more here.