The U.S. Coast Guard has created a handout containing 10 common deficiencies found during its exams of uninspected towing vessels.
The list, compiled by the Towing Vessel National Center of Expertise (TVNCOE) in Paducah, Ky., was done in conjunction with the Towing Vessel Bridging Program. That program was launched by the Coast Guard in 2009 to help owners and operators correct problems and prepare for new safety rules under Subchapter M.
Subchapter M regulations, authorized under the Coast Guard and Maritime Transportation Act of 2004, are unlikely to be implemented this year. But the agency is on its way to examining 6,050 towing vessels nationally. More than 5,700 exams have been done since 2009.
Photo courtesy U.S. Coast Guard
Examiner MST1 Kevin Cador checks the data plate on an unfired pressure vessel inside the boat.
From September 2009 to February 2013, staff at TVNCOE reviewed entries made by vessel examiners in the Coast Guard’s Marine Information for Safety and Law Enforcement (MISLE) database. The center identified 10 frequently observed deficiencies and in some cases suggested corrective action. Applicable regulations are in parentheses:
—Improper location of remote fuel shutoff valves. (As required by 46 CFR 27.207) Any line that supplies fuel directly to an engine or generator must have a shutoff valve that can be remotely operated from outside that space and as closely as possible to the fuel source. Mechanical linkages must be kept clean and lubricated. Valve controls must be labeled and must indicate actions, such as “Pull,” in 1-inch letters.
—Improper installation of general alarms. (Required by 46 CFR 27.201) Missing placards, missing or malfunctioning visual indicators and inoperable audible indicators are frequent deficiencies. An alarm must be installed in the engine room and any other area where noise makes it difficult to hear. A supplemental, flashing red light may be required, with a sign saying “Attention General Alarm – When Alarm Sounds Or Flashes Go To Your Station.”
—Improper navigation lights. (Required by 46 CFR 25.10-3) Incorrect vertical arrangement and improper types are problems. Operators should test navigation lights before each voyage and inspect them periodically. Household bulbs aren’t acceptable.
—Inadequate drug and alcohol testing and improper records of tests. (Required by 46 CFR 4.06-15, 16.230 and 16.401) Random testing, testing after a serious marine incident, employee assistance programs and record keeping on tests are all required.
—Fire detection control panels that aren’t fully functioning. (Required by 46 CFR 27.203) A system’s installation must be certified by an engineer or classification society. Owners should have relevant documentation on board.
—Improper logbook entries or failure to record needed information. (Required by 47 CFR 80 and 33 CFR 164.80) Many vessels aren’t in compliance with regulations requiring records on equipment tests, inspections and operational details.
—Improper or non-functioning vessel compasses; and for Western River operators, improper or non-functioning swing meters. (Required by 33 CFR 164.72) Compasses must be illuminated, card-type, magnetic and readable from the main steering station. Swing meters must be illuminated.
—Malfunctioning marine sanitation devices. (Required by 33 CFR 159.7) Towing vessels must have a working Coast Guard-approved Type I, II or III system aboard. Operating instructions and treatment chemicals must be on board.
Photo courtesy U.S. Coast Guard
A Coast Guard examiner looks at structural damage on a towing vessel’s deck during an industry-initiated exam.
—Improper installation of fire extinguisher brackets. (Required by 46 CFR 162.028(g)) Brackets must hold extinguishers securely in their stowage locations and must allow quick release of the extinguisher. Some extinguishers arrive from manufacturers with improper brackets that need to be changed.
—Improper official number markings on vessels. (Required by 46 CFR 67.121) Commercial vessels in excess of 5 net tons must be documented under federal law. An officially assigned number must be permanently fixed to a major structural part of the vessel in the format “No. XXXXXXX.” The number can be welded, tapped, scribed, engraved or otherwise fixed to a bulkhead, frame, beam or other structure so that it can be readily observed.
The top 10 list was developed from compliance with regulations, and it doesn’t address specific operations or equipment that may pose hazards, the Coast Guard said. To view the list as it was first published in the TVNCOE handout, visit www.uscg.mil/TVNCOE/Documents/Handouts/Top10defsMay2013.pdf.
When asked which deficiencies are the most difficult to correct, Steven Douglass, national technical adviser at TVNCOE, said they’re dealt with on a case-by-case basis. “The most difficult to correct can vary with the construction idiosyncrasies of each vessel,” he said.
Some deficiencies cost more to correct than others, according to Michael White, New Orleans-based towing vessel safety coordinator in the Coast Guard’s Eighth District. “Firefighting systems and fire detection systems, for example, can be expensive,” White said. “And vessel owners are always concerned about costs.”
At the American Waterways Operators (AWO) in Arlington, Va., Government Affairs Manager Brian Vahey said the Coast Guard’s top 10 list is a good one overall and a big step toward helping operators identify deficiencies that can be overlooked. “But the Coast Guard and industry recognize that not every deficiency included on the list has the same impact on a vessel’s safe operations. Things like logbook requirements are less important to overall safety than fire-detection control panels, general alarms and navigation lights,” he said.
The Coast Guard and AWO have discussed expanding the top 10 list eventually to include some deficiencies that may be less common but have big safety impacts, Vahey said. Those deficiencies will be identified through the bridging program, he said.
Photo courtesy U.S. Coast Guard
Cador takes a close look at fuel shutoff piping in the engine room. Mechanical linkages must be kept clean and lubricated. Valve controls should be properly labeled.
“The tugboat, towboat and barge industry prides itself on its safe track record,” Vahey said.Pinpointing common deficiencies reinforces the notion that there’s always room for improvement.
The Coast Guard partnered with AWO to develop its Towing Vessel Bridging Program. Phase I of the program, which began in 2009, focused on voluntary exams. Phase II started in July of last year and concentrates on reinspected towing vessels that haven’t had a voluntary exam. Upcoming Phase III exams will address Subchapter M implementation once final rules are published.
Participation in the bridging program is voluntary, Douglass said. “Any uninspected towing vessel that’s had an exam has met the program’s main objective,” he said.
In their inspections, towing vessel examiners are looking for compliance with Subchapter C, White said. Subchapter C covers uninspected passenger vessels. “We’ve been involved in this effort for quite some time and have a standard exam,” he said.
Pass/fail rates do not apply to towing vessel exams. “We don’t fail them,” White said. “If we find deficiencies, we give the owner 30 days to make corrections and then we reinspect the vessel. After problems are corrected, we issue a decal good for three years, indicating that they’re in compliance with Subchapter C.”
Vessel owners and operators are encouraged to have re-exams after their decals expire. “This isn’t required, but it’s a good practice,” White said.
With 5,700 uninspected towing vessel exams conducted since 2009, about 350 exams remained to be done under the bridging program as of July 8. Most vessels inspected since 2009 have met and in many cases exceeded minimum Subchapter C requirements, Douglass said.
Examiners have been busy in recent years. The Coast Guard inspected 354 towing vessels in 2009 and picked up its pace to 1,904 in 2010. In 2011, 1,585 exams were conducted, followed by 1,581 exams in 2012. Between January and July 8 of this year, 312 exams were done, the agency said.
In six districts out of the Coast Guard’s nine, over 80 percent of towing vessels had been inspected from the 2009 start of the bridging program through July 8 of this year. Two of those districts, D8 and D14, had reached 94 percent and 97 percent complete, respectively. D8, headquartered in New Orleans, is the largest district, covering all or part of 26 states, and it has 3,800 towing vessels.
Three districts — D13, D5 and D17 — lag the other six in exam completions, the Coast Guard said. Those districts were less than 75 percent done.
As for Subchapter M, Vahey said if the Coast Guard decides to issue an interim final rule this year, the inspection regime will begin. “But the Coast Guard would plan to implement Subchapter M in a staggered way so that all towing vessels will not have to comply immediately,” he said. “And from everything I’ve heard, it’s unlikely that the next version of the inspection rulemaking will be published in 2013.”