01/02/2019
Excerpt from the Coast Guard Maritime Commons
The Coast Guard has increased the minimum random drug testing rate for 2019 as a result of Drug and Alcohol Management Information System data for the most recent reporting year indicating that the positive rate is greater than one percent.
Click here to access the full post from the Coast Guard Maritime Commons
11/07/2018
Excerpt from the Coast Guard Maritime Commons
The Marine Safety Center revised the GEN-05 Review of Stability Test Procedures on 10/16/2018.
This Plan Review Guideline provides general guidance and information for conducting successful stability tests and submitting stability test procedures to the MSC. It applies to vessels certificated under any subchapter of 46 CFR.
Plan Review Guidelines were developed by MSC staff and are provided as an aid in the preparation and review of vessel plans and submissions. They were developed to supplement existing guidance and are not intended to substitute or replace laws, regulations, or other official Coast Guard policy documents. For more information about PRG, contact the MSC at msc@uscg.mil or 703-872-6730. When contacting MSC, reference the PRG by procedure number, e.g. GEN 05.
GEN-05 Review of Stability Test Procedures
Click here to access the full post from the Coast Guard Maritime Commons
On 10/03/2018, the USCG Eighth District (D8) issued a memorandum canceling its Towing Vessel Inspections Field Notice, D8-TVIFN 18-1 Operational Enforcement Discretion, dated 01/24/2018, commonly referred to as “Deferred Enforcement,” with the publication of the national policy document CVC-WI-010(1) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels, dated 10/02/2018. Download links for both documents can be found below.
WHAT DOES THIS MEAN FOR YOU?
If you have findings (non-conformities and/or deficiencies) from audits, surveys, self-reporting, etc. related to areas previously addressed by the D8 letter or the new national policy document and have developed corrective action plans (CAP) that were consistent with the deferred enforcement language you may need to update your CAP to address the findings in a manner that is consistent with the national policy (CVC-WI-010(1)).
The national policy work instruction document removes the “deferred enforcement” option and leaves operators with three options for addressing the following items:
NOTE:The national policy work instruction did not address all items from the D8 letter such as Visual Distress Signals. With the field notice cancelled by D8, the option for deferred enforcement is no longer a viable option for compliance. This does not prevent the operator from requesting special consideration from the OCMI or an equivalency from the MSC as noted below.
THREE COMPLIANCE OPTIONS UNDER CVC-WI-010(1)
If you have open findings on a CAP where the “deferred enforcement” was referenced as the corrective action with plans to correct prior to the first renewal of the COI or when USCG provides additional guidance you MUST update the CAP to be consistent with the national policy by choosing one of the three options above.
As a reminder, the corrective action process is an ongoing activity. During annual internal audits, annual surveys (internal or external) and external management and vessel audits the relevant corrective action plans will be reviewed to determine if findings have been closed along with reviewing open items for their progress.
CVC-WI-010(1) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels
