TVIB News Subchapter M Updates

USCG Oversight Workshop

Written by

This week TVIB’s staff participated in the first annual USCG Oversight Workshop at Sector Houston-Galveston. The newly formed Flag State Control Division CG-CVC-4, headed up by CDR Michael Simbulan, put together a 3-day workshop. In his opening remarks, RADM John P. Nadeau, Assistant Commandant for Prevention Policy, told the USCG personnel in attendance that they are charged with being “ready, relevant and responsive.” He finished his comments by telling all in attendance “We’re in this together. TPO failure is Coast Guard failure. Their success is our success.” TVIB staff took this as a very encouraging sign and believe it’s to our mutual benefit to establish solid working relationships.

 

“We’re in this together. TPO failure is Coast Guard failure. Their success is our success.” RADM John P. Nadeau, U.S. Coast Guard Assistant Commandant for Prevention Policy

The first day was attended by TPOs, classification societies and USCG marine inspectors from around the country. The next two days were scheduled for the marine inspectors only, to conduct training on the oversight activities of CG-CVC-4. This division was stood up as a result of the investigation from the El Faro and the need for increased oversight for third parties that conduct activities on behalf of the Coast Guard. The oversight responsibilities of this new division are much broader than Subchapter M.

TVIB was asked to discuss Subchapter M from a TPO Perspective. Chris Parsonage, Executive Director for TVIB, addressed the role of a TPO, TPO responsibilities, the survey and audit reports and their function as objective evidence, and the relationship between the TPO and the USCG. Chris finished with the benefits of the TSMS option such as improving safety and operational effectiveness as well as the recently highlighted opportunity for TSMS option vessels to request their TPO to clear deficiencies noted on a CG-835V. We’ll be working directly with our TPO customers in the coming days to ensure they know how to take benefit of this option. Calling on your TPO to clear a deficiency is likely to expedite the process of clearing out deficiencies if an operator does not have to wait on a marine inspector. Our auditors and surveyors are generally available and willing to go out when called.

TVIB staff also had the opportunity for a one-on-one conversation with RADM Nadeau where we were able to communicate issues that we face as a TPO as well as those faced by our TPO customers. This presented an opportunity to advocate for a simplified COI application process that would be used consistently from district to district and OCMI to OCMI. We are preparing a marked-up vessel particulars document in hopes of streamlining the data collection activity for the marine inspector by eliminating questions that are not relevant to inland towing vessel operations or helping to clarify terminology.

TVIB appreciates the opportunity to participate in this forum. We had access to leadership from the TVNCOE with CDR Andrew Bender and CG-CVC with Capt. Matt Edwards. Any time we can get together to share concerns and develop strategies we increase understanding all around.  This forum presented us with an opportunity to put faces to names for many of the sector and unit personnel we regularly work with. We thank all of our industry partners and the marine inspectors that came in for this session.

 

 

USCG: Updated Subchapter M FAQs

Written by

09/05/2018 Excerpt from Maritime Commons

Updated Subchapter M FAQs now available

Posted by LT Amy Midgett, Wednesday, September 5, 2018

The Towing Vessel National Center of Expertise recently published the latest additions and updates to the Frequently Asked Questions regarding Subchapter M, inspected towing vessels. As a convenience for our readers, in this post Maritime Commons is providing a compilation of those changes.

Click here for the compilation from the Maritime Commons: Subchapter M FAQs added or updated as of Aug. 27, 2018

Click here to access the full library of FAQs regarding Subchapter M.

USCG: Recap of USCG-AWO Steering Committee Meeting

Written by

Reposted from the Coast Guard Maritime Commons

08/09/2018: Recap of Coast Guard-American Waterways Operators Steering Committee Meeting

Posted by LT Amy Midgett, Thursday, August 9, 2018

The Coast Guard-American Waterways Operators Safety Partnership held its National Quality Steering Committee meeting July 31, 2018, with an agenda focusing on the concerns of the partnership and industry.

The Coast Guard/AWO partnership was formalized with a memorandum of agreement in 1995, after recognition that each organization shared the common goals of improving towing industry safety and increasing environmental protections. The partnership is a non-regulatory body that promotes sharing of best practices, waterways management and professional cooperation.

This meeting marked the first NQSC meeting since Subchapter M towing vessel regulations went into effect July 20, 2018. So far, 41 towing vessels have received an initial Certificate of Inspection, leaving approximately 5600 over the four-year phase in period.

“I’m very proud of the work done by towing vessel owners and operators, Third Party Organizations, the Towing Safety Advisory Committee, the Coast Guard Towing Vessel National Center of Expertise, our experts at Coast Guard Headquarters, and Coast Guard personnel across the nation over the last 15 years to get us to where we are today with Subchapter M implementation,” said Rear Adm. John Nadeau, assistant commandant for prevention policy, during his opening remarks. “We are not done yet, but we should all pause and acknowledge everything that’s been accomplished to successfully get us here.”

Nadeau said the Coast Guard is focused internally on its marine safety and prevention program, noting that marine inspector training, third party oversight, and a strategic outlook toward safeguarding the Marine Transportation System are early priorities for the new commandant, Adm. Karl Schultz.

Nadeau and AWO Co-Chair Tom Allegretti then led an open discussion about some of the challenges and future goals associated with Subchapter M. A few of the topics discussed included:

  • The importance of TPOs’ role in achieving compliance
  • The need for a standardized approach for authorizing temporary, mission-specific operations outside a tug’s established boundary line
  • Improving communication with TPOs
  • Incentivizing the TSMS option over the Coast Guard option
  • Future Coast Guard policy addressing low risk requirements

“The Coast Guard is dedicated to ensuring TPOs succeed; their success is our success,” Nadeau said to National Quality Steering Committee members. “Owners and operators of TSMS vessels should make their TPOs their first stop for questions, and, in turn, TPOs have head of the line access to my staff at Headquarters and at the Towing Vessel National Center of Expertise.”

The meeting also included updates from workgroups and quality action teams on the progress of new initiatives and policy/regulatory implementations.

  • The Subcommittee on Operational Crew Fatalities presented findings of its study on crew deaths resulting from falls overboard, which account for 48 percent of all operational fatalities on towing vessels. The subcommittee is developing a training regimen to address the issue and will present its recommendations at the AWO safety conference later this year.
  • The Towing Industry Cyber Management Team presented a draft best practices guide to assist towing companies of all sizes to assess their cyber vulnerabilities and develop a risk management plan for preventing a cyber incident and how to remain resilient should one occur.
  • The Fatigue Risk Management Working Group briefed attendees on a draft plan to help the towing industry manage and mitigate risk factors associated with fatigue in the unique operational and environmental challenges in which they work. The plan covers four core elements: education, environment, work readiness and fatigue reporting, and performance management. AWO expects to release the guide later this summer.

To close the meeting, Nadeau said moving forward with Subchapter M implementation, the Coast Guard will focus on three key elements: third party oversight, emphasizing the importance of using a safety management system to manage risk, and redoubling efforts to help TPOs understand their roles, responsibilities, and authorities under Subchapter M.

Click here for the original post on Maritime Commons.