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USCG: Is your Automated Identification System ready for Subchapter M?

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Reposted from the Coast Guard Maritime Commons

7/3/2018: Is your Automated Identification System ready for Subchapter M?

Posted by LT Amy Midgett, Tuesday, July 3, 2018

Submitted by Lt.j.g. David Turay, Coast Guard Navigation Center

A vessel’s Automatic Identification System (AIS) is crucial to the crew’s safety. AIS is a situational awareness tool that was originally intended for collision avoidance, but it has many other applications:

  • SAR – Aids first responders in reaching vessels in distress.
  • Vessel Traffic Service (VTS) – AIS is used by surveilled VTS systems to provide additional navigation safety in busy ports and waterways.
  • Fleet Monitoring/Tracking – AIS is a cost effective way for operators to monitor their fleet activities.
  • Accident Investigations – Historical AIS data is important to thorough accident investigations, which identify ways to further improve maritime safety.

AIS broadcast is autonomous and continuously exchanges real-time safety and navigation information between AIS equipped vessels within VHF range of each other. Recognizing the critical role AIS has on our nation’s maritime safety and security, the Coast Guard developed the Nationwide AIS (NAIS), which consists of an expansive network of shore-based VHF towers that receive AIS transmissions from vessels transiting U.S. waterways.

AIS Data

AIS data falls into three categories: Static, Dynamic, and Voyage-related Data.

Static Data is information that must be programmed into the AIS at installation and is verified periodically. Static Data includes: Maritime Mobile Service Identity (MMSI); vessel type; vessel name; call sign (if assigned); IMO or Official Documentation Number (if assigned); and antenna location (which is also used to provide vessel dimensions).

Dynamic Data, such as position, course, speed, heading, and rate of turn is autonomously acquired from external or internal sensors (i.e. GPS, speed log, heading device or gyro). Dynamic Data is continuously broadcast every few seconds. Proper installation and operation of all sensors is critical to the proper operation of AIS and the accuracy of the information it exchanges.

Voyage-related Data (i.e. Navigation status, static draft, destination, and estimated time of arrival) is manually entered and should always be kept up to date. Navigation status must be updated throughout the course of a voyage. Vessels underway broadcast every 2-10 seconds, whereas vessels that are moored or at anchor broadcast every 3 minutes. Moored vessels that use an underway navigation status consume significantly more NAIS bandwidth. Bandwidth and throughput are crucial factors that may affect the response times of first responders that use NAIS information. Vessels should use the correct navigation status to remain compliant with federal regulations and to ensure NAIS performs at optimal levels.

Subchapter M and AIS

During the month of June 2018, over 50 percent of towing vessels operating in U.S. waters transmitted incorrect AIS data, and an alarming number of these vessels did not accurately report their dimensions or broadcast a properly assigned MMSI number. Failure to accurately report a vessel’s dimension significantly increases the risk of collision, especially in congested waterways or during low visibility conditions. Knowing the location of the bow in addition to the overall length of the vessel and associated barges is crucial to help approaching vessels react and maneuver appropriately. This is especially important when visibility is limited.

Subchapter M regulations bring numerous new requirements to the towing community. Vessel operators will be required to adhere to these new regulations in addition to the existing regulation for all AIS users, the AIS Carriage Requirement found in 33 CFR 164.46d(2). It requires vessel AIS to be maintained in effective operating conditions, which includes the broadcast of a properly assigned MMSI and all other AIS data fields.

AIS is a valuable navigation safety radio communication tool. However, its effectiveness is undermined by the broadcast of inaccurate, improper or outdated data. The deliberate broadcast of inaccurate AIS data may subject violators to monetary penalties by the Coast Guard, and operators may also be subject to significant penalties by the FCC for each violation of improper or inaccurate MMSI broadcast. Fortunately, the AIS carriage requirement is one of the easiest regulations to meet before scheduling vessel inspections.

Guidance and Verification

To assist AIS users, the Coast Guard has promulgated a two-page AIS Encoding Guide. The Navigation Center is also the home of the Vessel Information Verification Service (VIVS), a web-based self-help tool that allows users to check their vessel’s AIS data. VIVS search results will highlight any suspected AIS static data discrepancies. Towing vessel operators can then use this information to make any necessary corrections before scheduling vessel inspections.

Click here for the original post on Maritime Commons.

USCG: Subchapter M – Certificates of Inspection (COI)

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Reposted from the Coast Guard Maritime Commons

7/2/2018: Collecting information for Subchapter M certificates of inspection

Posted by LT Amy Midgett, Monday, July 2, 2018

Submitted by Cdr. Jennifer Hnatow, Domestic Compliance Division, Office of Commercial Vessel Compliance

As of June 25, 2018, the Coast Guard has issued 22 certificates of inspection (COI) to towing vessels in both the Atlantic and Pacific areas of operation. Additional inspections are scheduled between now and July 20, 2018, when Subchapter M is fully implemented. Following are several important points to keep in mind when seeking a COI:

  • The requirements for obtaining a certificate of inspection, as detailed in 46 CFR 136.210, begin when the owner/operator submits the Office of Management and Budget (OMB) approved Form CG-3752“Application for Inspection.” New construction vessels use Form CG-3752A. Owners/operators are only required to complete OMB-approved forms and submit the information listed in the regulations.
  • In order to collect other necessary information, marine inspectors may use job aids or checklists to help document and organize all the required information. Form CVC-FM-004(1) – “Towing Vessel Particulars,” is one example marine inspectors may use. These forms are for the marine inspectors, not owners/operators, to fill out. The marine inspector will complete the job aid/checklist using input from the owner/operator before, during, or after the initial inspection. This input could include information gained from verbal interviews, visual inspection, or review of system manuals and other pre-existing vessel documentation the owner/operators provides to the marine inspector.
  • To decrease the disruption to the vessel’s operation, the Coast Guard recommends that vessel owners/operators make any pre-existing vessel documents readily available to the marine inspector during the initial inspection. Doing so may reduce the marine inspector’s time on board the vessel and alleviate the need for follow up visits.

There is less than four weeks to go before towing vessels are required to comply with the provision ins 46 CFR Subchapter M. Owners and managing operators are encouraged to work with their local OCMI and develop a plan to ensure their vessel(s) are in compliance, allowing adequate time for the Coast Guard or a Third Party Organization to complete the required inspections, audits, and surveys necessary prior to the issuance of a COI.

For Coast Guard Subchapter M policy letters, visit the Office of Commercial Vessel Compliance’s website or the Towing Vessel National Center of Expertise’s website.

Click here for the blog post on Maritime Commons

July Training Opportunities – Space Is Limited

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TVIB and ACTSafe Training are hosting a Subchapter M suite of courses in Houston the week of June 9th – Space is Limited.  You can register for all three courses or just the one(s) needed.  Each course builds upon the other.  If you’ve already taken the MILA course consider expanding your depth of knowledge and exposure to critical Subchapter M elements. See below for course descriptions and links for registration.

Marine Internal Lead Auditor (MILA) – July 9-10 – Houston, TX – Marine Internal Lead Auditor

TVIB has partnered with ACTSafe Training in this Coast Guard recognized Marine Internal Lead Auditor course, designed to teach the specific skills and knowledge necessary to conduct and lead internal audits for commercial marine companies.

The course meets the requirements of ANSI Z 490.1 Criteria for Accepted Practices in Safety, Health and Environmental Training and the requirements of 46 CFR 138.310(d)(2).

Course Information and Registration

Risk Management – July 11 – Houston, TX

The RCP requires risk a risk process and most companies are not providing training in how to conduct risk assessments. This course is written by the author of the RCP risk section (Rick Dunn). Persons taking this class will leave with simple risk tools that can be used in the workplace. With Subchapter M becoming law in 2018, it makes sense to ensure your risk process meets the ISO 31000 risk standard.

You will learn:

  • Risk management vs Risk Assessment
  • The Risk Pyramid
  • RCP, TMSA3, Sub M risk requirements
  • Review key risk tools and concepts of ISO 31000
  • Failure Effects Mode Analysis (FEMA) risk methodology
  • How to use risk tools to assist in creating a Permit to Proceed Process for COI discrepancies under Subchapter M
  • How to conduct hazard bases qualitative risk assessments (format provided)
  • How to implement a simple yet effective JSA process

This course is suitable for managers, safety personnel, vetting advisors (oil majors and operators), regulators, operations managers and Port Captains.

Course Information and Registration

Subchapter M TSMS Objectices for Designated Persons – July 12 – Houston, TX

As the industry enters into a “regulated management system” world, the TSMS becomes critical to managers and those serving as Designated Persons under RCP or the ISM Code. This course is designed to help management and individuals protect their interests while demonstrating they are meeting the TSMS objectives of Subchapter M. The current language in Sub M appears to expose management and DPAs should a major incident occur or if a third party challenges their TSMS methodology. This course explores how best to protect your interests while making the TSMS more effective.

You will learn:

  • The history of the DPA with a case study review
  • Understanding how to meet the purpose of a TSMS for USCG and Customer needs
  • Critical success factors for marine managers and operations personnel
  • Management of Change concepts
  • Importance of Hierarchy of Controls in a TSMS improvement process
  • Each TSMS objective in Sub M is reviewed and methods to demonstrate how to meet them are discussed and explained
  • How to improve your internal audits to demonstrate compliance with the objectives
  • How to use Management Reviews to maximize compliance and improve effectiveness
  • Details of how the best operators ensure that their TSMS meets the objectives and is effective

This course is suitable for managers, DPA’s, safety personnel, vetting advisors (oil majors and operators), regulators, operations managers and Port Captains.

Course Information and Registration