1Towing Vessel InspectionInland Rivers and Gulf Coast – 2013Towing Vessel InspectionSection 89/10/2013

Navigation Safety Panel Discussion2ModeratorTava ForetCoast Guard PerspectiveLT Edward AyoubMST1 Bryan VitranoIndustry PerspectiveTava ForetTom McWhorterTowing Vessel Inspection9/10/2013


4Towing Vessel Inspection9/10/2013

The Good5Towing Vessel Inspection9/10/2013

The Bad6Towing Vessel Inspection9/10/2013

The Ugly70300September 23,199347DEADCaused by Towing Vessel’s Pilot becoming disoriented in heavy fog and striking bridge.Deadliest accident in Amtrak’s history – Big Bayou Canot Bridge, Mobile, ALTowing Vessel Inspection9/10/2013

American Waterway Operators8 1994 – Established its own voluntary “Responsible CarrierProgram” Operations incl. fuel transfer proceduresSafety TrainingEnvironmental policyIncident ReportingEmergency Response and EquipmentTowing Vessel Inspection9/10/2013

American Waterway Operators9 1998 – Made “Responsible Carrier Program” mandatory forits members. Must undergo 3rd party auditsBy 2000 all members had been audited (10% every 3 years)13 companies left the organization rather than face the audit.Towing Vessel Inspection9/10/2013

Maritime Transportation Act of 200410Towing Vessel Inspection9/10/2013

11Towing Vessel Inspection9/10/2013

Summer 2009Phase 1 Began12 108 Dedicated Billets – New UTV Examiners are qualified/knowledgeable and build industry partnerships.Establishment of an NCOEFunding for TrainingIndustry Initiated Exams (IIE)Decal IssuanceTowing Vessel Inspection9/10/2013

A Phased Approach 13Summer 2009Phase 1 Outreach & Education IIEs Testing of Risk Tool Qualification/PQS Id of FOFRsTowing Vessel Inspection01JUL12Phase 2 Prioritized Exams Course Development Comments on NPRM 100% FOFRs examinedSubchapter “M”PublishedPhase 3 COI Issuance Formal Training9/10/2013

Phase II14 Began 01JUL12 Phase II wasn’t supposed to start until ALL Districts wereready Port State Information eXchange (PSIX) was supposed tobe enabled Industry Initiated Exams to continue in Phase II and totake priorityTowing Vessel Inspection9/10/2013

Targeting Matrix15Towing Vessel Inspection9/10/2013

MSU Port ArthurApprox. 65 UTVs1614%20%Decaled IssuedDecal Not IssuedUnexamined*66%*0 vessels in operationleft to be examined.Towing Vessel Inspection9/10/2013

Future of MSU PA UTVs17 Continue Phase II efforts Ramification of SIRE Inspections Decal RenewalsTowing Vessel Inspection9/10/2013

Total FOR 50918MSU Port Arthur 65Sector H/G 329MSU Lake Charles 79MSU Texas City 369/10/2013

Compliance Issues19 After more than 6300 uninspected towing vessel exams,some key issues have surfaced.Towing Vessel Inspection9/10/2013

Current Compliance Issues20Fuel Shut-Off Valves required by 46 CFR 27.203 LocationMarkingOperationGeneral Alarms required by 46 CFR 27.201 MarkingSupplemental flashing red lightNavigation Lights required by 46 CFR 25.10-3 Technical standardsApproved typeTowing Vessel Inspection9/10/2013

Current Compliance Issues21 Drug & Alcohol Testing/Records - 46 CFR 4.06 & 16 Testing devices - expiration date/improper stowageRecord keeping - random testingEAP Program - display and distribution of training materialsRecordkeeping – 47 CFR 80 & 33 CFR 164.80 Radiotelephone logs maintenance and entriesRecord of test and inspections before getting underwayTowing Vessel Inspection9/10/2013

Current Compliance Issues22 Magnetic Compass/Swing Meter - 33 CFR 164.72 Not fitted or functioningWrong equipment for area of operationNot properly illuminatedFire Detection Equipment - 46 CFR 27.203 Panel inoperablePanel not properly labeledProof of PE certificationMarine Sanitation Devices - 33 CFR 159.7 Not properly labeledNot properly secured against overboard dischargeInadequate supplies for proper operationTowing Vessel Inspection9/10/2013

Current Compliance Issues23 Vessel Markings - 46 CFR 67.121Official Number not in accordance with requirementsOfficial Number not permanently fixed Fire Extinguisher Brackets - 46 CFR 162.028-3Not approved type Pressure Vessels *******Missing data platesImproper PV valvesNonstandardImproper repairsNote: Not currently regulated on UTV’s but my be classified as a HazardousConditionTowing Vessel Inspection9/10/2013

Towing Vessel National Center of ExpertiseTOWING VESSEL NATIONAL CENTER OF EXPERTISEOFFICE: (270) 444-7715 (X-203)FAX: (270) 444-8094Web Address – WWW.USCG.MIL/TNVCOE

Industry Perspective259/10/2013

Towing Vessel Inspection Bureau26 What one segment of the Towing Vessel industry is doing toprepare for Towing Vessel Inspections under 46 CFRSubchapter M9/10/2013

The Future of Auditing27 Following the evolution of the TSAC Subchapter M processthat began in 2004 that included: the review of 2 sets of draft language,the publishing of the NPRM in August of 2011,and the public hearings, It appeared there was an area of Subchapter M that neededmore attention9/10/2013

More Work To Be Done28 There were several issues to consider: Would there be enough qualified auditors for Sub M?How would they be trained?What would happen if there were 20 different accepted organizations, eachusing different methods for conducting audits and each and submittingdifferent audit reports?Could the Industry and Coast Guard reasonably expect consistency inauditing?With inevitable inconsistency could there be long-term acceptance of Sub M?What would be the fallout?Who would suffer most from any push back?9/10/2013

A Solution29 Formation of TVIB as a Professional Trade Organization forMarine Auditors and Surveyors to: Review credentials, experience and work historyDevelop a common audit tool for management and vessel auditsProvide Training on the Regulatory StandardSet Member Standards and GuidelinesAdvocate on behalf of the Auditor Member9/10/2013

What Is TVIB?30 Non-profit organization formed in 2010 Filed for 501(c)(6) in 2013 Two Member Categories: Auditor MembershipSupporting Organization Membership Member-owned and governed Organization was turned over to the membership in May of2013 and is now governed by the 21-member Board ofDirectors and an Executive Director9/10/2013

Purpose, Goals and Objectives31 Train and certify members to conduct audits andinspections Perform the training and accreditation function for theAmerican Waterways Operators Responsible CarrierProgram (RCP). Pending the Final Rule – Conduct training andaccreditation function for auditors/surveyors working forUSCG accepted organizations providing third-party auditsand/or surveys under Subchapter M9/10/2013

The AWO Responsible Carrier Program 32 Early Fall of 1993 – External and Internal Factors April 1994 – Development of the RCP April 1998 January 1, 2001 – 100% of the AWO Carrier Members werein compliance SIDE NOTE – 2004 Subchapter M began 2008 – the board voted to get out of the auditoraccreditation business and later reaffirmed that decision 2013 - TVIB entered into a 10-year agreement to assumethe RCP Auditor Accreditation and Training Function fromAWO9/10/2013

AWO-TVIB Agreement Overview33TVIB will provide the following in connection with the RCP: Certification of Auditors Conduct initial and recertification training Address auditor questions concerning the RCP TVIB will not directly oversee auditor’s performance of audits Provide Continuing Education to the Auditors Develop and administer procedures for appeals and grievances Develop and enforce a substantive Code of Ethics Utilize an internal quality system based on an ANSI/Amer.Society of Quality Control Q9001-2000 or equivalent and attainISO certification9/10/2013

AWO and TVIB – Today and Tomorrow34 Enhanced Management Checklist and Worksheet TVIB-Certified AWO RCP Auditor Course COMPLETED - August 6-8, 2013 - Houston, TXNovember 5-7, 2013 - Nashville, TNMarch 2014 – Location TBN TVIB Upcoming Meetings November 2013 – Board Meeting - Nashville, TNMarch 2014 – Annual Members Meeting/Board Meeting – Location TBN Enhanced Vessel Checklist(s) and Worksheet(s) 3-day Internal Auditor Course Evaluate the Development of an Electronic Audit Tool9/10/2013

Committee Structure35Auditor Accreditation and OversightCommitteeAuditor ResourcesCommitteeAuditor CertificationAudit Process Verifies Credentials Develop and continuously improvethe audit process Evaluates Qualifications Issues Final TVIB CredentialAudit ChecklistAuditor Training Prepares and conducts Initial andrefresher trainingAuditor Oversight and QualityControl Evaluates Auditors Addresses Auditor ComplaintsSubcommittees Develop and continuously improvethe audit checklist/toolContinuing Education Keep Auditor Pool up to date onchanges to the audit process andaudit checklist Provide other continuing educationopportunities to the Auditors9/10/2013


Navigation Safety Panel Discussion37ModeratorTava ForetCoast Guard PerspectiveLT Edward AyoubMST1 Bryan VitranoIndustry PerspectiveTava ForetTom McWhorter9/10/2013

Towing Vessel Inspection Coming up next: Western Rivers38Section 89/10/2013

Towing Vessel Inspection 9/10/2013 . Current Compliance Issues . USCG accepted organizations providing third-party audits and/or surveys under Subchapter M 9/10/2013 31 . The AWO Responsible Carrier Program . Enh