U.S. Coast Guard issues list of
10 common towing vessel deficiencies
The U.S. Coast Guard has created
a handout containing 10 common deficiencies found during its exams of
uninspected towing vessels.
This list, compiled by the
Towing Vessel National Center of Expertise (TVN-COE) 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.
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 paraphrases:
-
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 test. (Required by 46 CFR 4.06-15, 16.230 and 16.401) Random
resting, testing after a serious marine incident, employee assistance programs
and record keeping on test 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 regulation with regulations requiring records equipment tests,
inspections and operational details.
-
Improper or non-functioning vessels compasses; and for
Western River operators, improper or non-functioning swing meters. (Required by
33 CFR 164.72) Compasses must be illuminated, cardtype, 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.
-
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 manufactures with improper brackets that need to be
changed.
-
Improper official number marking 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.
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 vessels#, 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 Eight District, “Firefighting
system and fire detection systems, for example, can be expansive”, White said.
“And vessel owners are always concerned about cost”.
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 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.
“The tugboat, towboat and barge
industry prides itself on its safe track record,” Vahey said. Pinpointing
common deficiencies reinforces that 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, Douglas 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, Douglas 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 en 2010. In 2011, 1,585 exams were conducted, followed by
1,581 exams in 2012. Between January and July 8 of 2013, 312 exams were done,
the agency said.
In six districts out 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 2013. Two of those
districts, D8 and D14, had reached 94 percent and 97 percent complete,
respectively, D8 headquarter 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”.
Recopilado
Capt
Guillermo Parra Avello
PROFESSIONAL MARINER
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