With the nationâ€™s first mandatory inspections finally visible on the horizon, the U.S. Coast Guard is beginning to inform the towing-vessel industry of the safety violations most often found during the current voluntary program.
Since the voluntary boardings began in June 2009, Coast Guard crews have taken note of repeated deficiencies with unfired pressure vessels (UPV), fuel shutoff valves, fire detection and suppression systems, and navigation lights. Generally, these are items covered under Part 27 of the existing regulations covering uninspected towing vessels.
|MST1 Thomas Link, a Coast Guard examiner, checks the diesel fuel fill station and containment on Bruce Darst on the Ohio River. (Photo courtesy U.S. Coast Guard Towing Vessel National Center for Expertise/William Perkins)|
â€œThatâ€™s been the dominant part that has stuck out. Thereâ€™s three or four issues with that part that keep coming up,â€ said Cmdr. Greg Case, commanding officer at the Coast Guardâ€™s Towing Vessel National Center for Expertise in Paducah, Ky.
The voluntary inspections are â€” for the industry and the Coast Guard â€” preparation for the long-awaited mandatory inspections, which have faced multiple delays in recent years. The industry should be able to review the plan in early 2011. The latest Coast Guard authorization signed by President Obama in October 2010 specified that the Coast Guard was required to announce the proposed rule within 90 days.
Because the concept of inspecting towing vessels is in its infancy, the Coast Guard isnâ€™t surprised to find many of the same deficiencies repeated again and again.
|The amber towing navigation lights on Bruce Darst. Improper bulbs in nav lights are one of the most common problems turned up during the inspections. (Photo courtesy U.S. Coast Guard Towing Vessel National Center for Expertise/William Perkins)|
â€œThe vessels havenâ€™t had much Coast Guard oversight until the last year,â€ Case said in an interview with Professional Mariner. â€œThat could be part of the problem. They havenâ€™t had the benefit of us being on board and steering them in the right direction.â€
The Coast Guard refers to the Phase 1 voluntary boardings as â€œindustry-initiated examinationsâ€ rather than inspections. Future Phase 2 exams will be compulsory for all uninspected towing vessels, as the Coast Guard and industry prepare for the mandatory inspections plan.
In the first 17 months of the voluntary program, a total of 41 operators have received flag letters from Coast Guard admirals congratulating them for having their entire fleets examined. The vessels receive decals indicating that theyâ€™re approved for three years.
|Capt. Richie Holshouser of towboat Alan Albright holds his safety decal. Others, left to right, are Coast Guard inspectors MST3 James Transano, MST2 Chris Moss, deck hand Kary Lee and fleet manager Larry Salyers. (Photo courtesy U.S. Coast Guard Towing Vessel National Center for Expertise/William Perkins)|
While some vessel owners are still not comfortable enough with their preparedness level to submit to a boarding, others appreciate the head start the voluntary program is giving the industry to see how the Coast Guard inspections might work.
â€œI totally endorse the way they are doing it,â€ said Joe Ferrell, the safety, security and regulatory compliance coordinator with tug-and-barge owner Gellatly & Criscione Services in Point Pleasant, N.J. â€œTheyâ€™re prepping the guys for the inspection process. Itâ€™s not like theyâ€™re just springing the inspections on us as soon as the mandatory (regulation) goes into effect. It eases everybody into the program.â€
The operators still probably have a couple years to get ready, and voluntary inspections will continue even after the proposed rule is announced in 2011, Case said. The interim rule will probably be published one year after the proposed rule, and then there will be a phase-in period and some old vessels will be grandfathered.
After almost one and a half years of voluntary inspections, the Coast Guard has identified hazards that require the operatorsâ€™ immediate attention. Among the most serious is carelessness with UPV relief valves, Case said. Although the pressure vessels are regulated by the Occupational Safety and Health Administration, the Coast Guard is warning the industry after inspectors repeatedly witnessed unsafe conditions. A relief-valve problem was the apparent cause of a St. Louis-area vessel explosion in 2009 that left one crewmember a paraplegic.
|The Coast Guard examiner is required to ensure that the fixed CO2 system designed to protect the engine room is being properly maintained by the owner/operator. (Photo courtesy U.S. Coast Guard Towing Vessel National Center for Expertise/William Perkins)|
Inspectors have noticed safety hazards including relief valves that are missing, wired shut, painted over or otherwise nonfunctional.
â€œTheyâ€™re supposed to be set at or below the maximum allowable working pressure,â€ Case said. â€œWe find mismatches, or it has seven coats of paint on it and thatâ€™s covering the opening.â€
Operators should check their UPVs to make sure theyâ€™re not corroded, that the relief valves are rated and maintained properly and that the data plate or documentation is still there.
â€œThey donâ€™t realize how much of a hazard that can be,â€ Case said. â€œItâ€™s a clear danger. You canâ€™t fool around with this.â€
Many boats also arenâ€™t equipped with the proper emergency fuel shutoff valves. Vessels are required to have a system in which a crewmember can cut off the fuel supply to the propulsion units in the event of an engine-room fire. Installing such a system, unfortunately, can cause a commercial disruption for the operator.
â€œThe big-ticket item as far as cost where we get some push-back by the industry is the fuel shutoffs,â€ Case said. â€œThe problem is, you may have to take the vessel out of service and put it in dry dock.â€
The system must be operable from outside the engine compartment, i.e., with a reach rod or pull cable.
â€œYou have to have a fuel shutoff, and it has to be a remote shutoff valve, because if you have a fire, you donâ€™t want to feed that fire with more fuel,â€ Case said. â€œAnd itâ€™s not just an engine shutoff â€” you would still have all that fuel spilling in and no way to shut it off.â€
Another surprise for some vessel owners has been the requirement that CO2 fire suppression containers must be stored outside the engine compartment.
â€œThe tanks canâ€™t be in the space youâ€™re protecting. Theyâ€™re designed to be outside, for the protection of the person setting the system off,â€ Case said. â€œBut with the configuration of the tugboats and towing vessels, there just isnâ€™t a lot of extra space outside the engine room where they can locate these, and they donâ€™t want them out in the weather.â€
Acceptable spaces for the CO2 containers include the aft steering compartment or forward hold, or the owner can build a deck enclosure.
Coast Guard inspectors are finding fire-detection systems that are unapproved or are missing their certification letters.
â€œTheyâ€™re supposed to have a professional engineer letter saying it was installed to certain specifications,â€ Case said. â€œDid someone oversee the installation so it was done properly?â€
Some towing companies seem to believe that the HillerSAFE fire and bilge flooding alarm system is Coast Guard-approved as an engine-room monitoring system. Case said it is not. The manufacturer is currently working on a testing regimen in an attempt to gain approval.
Vessels built after November 2002 are required to be fitted with certified navigation lights. Many vessel operators are replacing the certified marine bulbs with household bulbs. The light fixtures then are no longer certified lights because the fixtures and bulbs were tested together. Household bulbs donâ€™t sit in exactly the correct spot within the fixture and donâ€™t have the right kind of filament. They may not be visible from far enough away or at the proper angles or brightness. Owners need to use Perko lights that meet the UL 1104 standard or other brand equivalents.
â€œThe problem is, theyâ€™re expensive and sometimes they donâ€™t last as long as the boats would like them to, and instead they use household bulbs,â€ Case said. â€œBut that negates the whole apparatus.â€
The Coast Guard understands that regulations on lights have been modified many times in recent years, and itâ€™s no wonder mariners are confused about whatâ€™s allowed.
â€œFrosted household bulbs were really never approved for any of the running lights,â€ he said.
The Towing Vessel National Center of Expertise opened in May 2010. Case said the center already has hired separate experts covering bluewater and inland towing, plus firefighting, security, training, inspections and casualty investigations involving towboats. Operators may contact the center anytime with questions about regulations.
The voluntary and mandatory programs have been developed with the help of the Towing Safety Advisory Committee. Case said the Coast Guard and the industry generally are working well together during the current phase of the program.
â€œWe havenâ€™t had any problem with cooperation. Itâ€™s more of education and how can we do these without being onerous to the industry,â€ Case said.
Ferrellâ€™s company, which owns the tugs Mary Gellatly and Peter F. Gellatly, is getting ready for a voluntary inspection in 2011. He believes that operators who ignore the voluntary inspection may face more business disruptions later because they never prepared themselves for the mandatory program.
â€œItâ€™s a great idea to have the three-year decal instead of the one-year as a bridge into the (mandatory) inspections,â€ Ferrell said. â€œIf you donâ€™t take advantage of it and take the voluntary before these regulations go into effect, youâ€™re going to be in trouble.â€