A Bridge to Inspection Mr. Roy L. Murphy Senior Marine Inspector US Coast Guard Towing Vessel National Center of Expertise 270-444-7715 Roy.L. Murphy @USCG.MIL 1 4/5/2013
Towing Vessel Bridging Program Why do we need a bridge? 2 4/5/2013
Milestones
A Phased Approach Summer 2009 Phase 1 Outreach & Education IIEs Testing of Risk Tool Qualification/PQS Id of FORs Phase 2 Prioritized Exams Course Development Comments on NPRM 100% FORs examined Subchapter M Published Phase 3 COI Issuance Formal Training Law Enforcement Boardings & Surge Operations 4/5/2013 4
Phase 2 Prioritization Matrix High Priority Vessel Company has not participated in Phase 1 Vessel has not been examined Low Priority Vessel Company participating in Phase 1 Vessel has not been examined Non-Priority Vessel Company participating in Phase 1 Vessel has been examined Enclosure (1) 4/5/2013
UTV Fleet of Responsibility = 6139 Industry Initiated Exams = 5207 Prioritized Exams Remaining = 993 As of DEC 2012
Towing Safety Advisory Committee (TSAC) Established by Congress to Advise the Coast Guard on matters related to the towing vessel industry Consists of 18 members appointed by the Secretary of Homeland Security to represent specific segments of the towing vessel industry Members of the Towing Vessel Industry and the general public are encouraged to participate in both public meetings and subcommittee meetings. Please refer to the TSAC Fact Sheet handout for more information on how to participate at the next TSAC event
Towing Safety Advisory Committee Current Projects Task Statement 12-01 - Recommendations for the Prevention of Towing Vessel Crewmember Falls Overboard. Task Statement 12-02 - Review and Recommendations for the Revision of NVIC 1-95, Voluntary Training Standards for Entry- Level Personnel on Towing Industry Vessels. Task Statement 12-03 - Recommendations for the Enhancement of Towing Vessel Stability Task Statement 12-04 - Recommendations for Safety Standards of Portable Facility Vapor Control Systems Used for Marine Operations. Task Statement 12-05 - Recommendations to Enhance Fire Prevention and Containment Aboard Towing Vessels
Towing Safety Advisory Committee Current Projects (Cont.) Task Statement 13-01 Automatic Identification Systems (AIS) Encoding for towing vessels. Task Statement 13-02 - Recommendations for Inspected Towing Vessel Manning.
Towing Safety Advisory Committee Current Events The Fall 2012 meeting was held in Seattle Sept 19-20. An Intercessional, telephonic meeting was conducted on Jan, 16 2013. The Spring 2013 meeting is planned for March 20-21, 2013 in New York City. These meetings, with agendas, are announced in the Federal Register at least 30 days prior to the meeting. Members of the public are encouraged to attended and participate on TSAC sub-committees as needed.
CURRENT COMPLIANCE ISSUES After more than 5000 uninspected towing vessel exams, some key issues have surfaced. 4/5/2013 11
Non-Standard Pressure Vessels
Navigation Lights 46 CFR 25.10 Vessels built after Nov. 7, 2002 are required to be fitted with certified nav lights. Any certified fixture that is modified to fit any bulb other than what s specified for use by manufacturer voids the certification. 4/5/2013 13
Fixed Systems CO 2 systems with over 300lb capacity are located inside the space being protected. Inadequate amounts of CO 2 to protect the space. 4/5/2013 14
Fuel Shut-Off Vlaves Valve installed at the engine instead of near the tank. Valves not functional Valves not labeled properly 4/5/2013 15
Fire Detection System 46 CFR 27.203 Control Panel location Not CG approved or listed by independent testing laboratory Documentation by PE or NICET Level IV Tech. HillerSAFE Systems
Non-Standard Pressure Vessels Case Study
The Issue Not currently regulated by CG Explosion hazard Missing data plates Inoperable or improper relief valves Lack of maintenance Policy Hazardous Condition Marine Safety Alert Towing Vessel National Center of Expertise
Proposed Process A process to establish the maximum allowable working pressure (MAWP) on existing non-standard pressure vessels Requirements: Certified Contractor National Board of Boiler & Pressure Vessel R Stamp holder Authorized Inspector (AI) (National Board Commissioned Inspector (NBCI) Professional Engineer (PE) Determines maximum allowable working pressure (MAWP) Documentation National Board/MISLE
Proposed Process 1. External and internal visual inspections 2. Non-destructive testing & Positive Material Identification 3. Professional Engineer use Ultrasonic and PMI test results to establish maximum allowable working pressure (MAWP) 4. Hydrostatic test performed 5. Data Plate created and affixed to PV 6. Documented by National Board /MISLE
Servicing Qualifications Coast Guard has no Fire Suppression System Servicing Company Qualification Process. Towing Vessel National Center of Expertise
Maintaining Fire Suppression Systems 46 CFR 27.100(d) Fire Fighting Equipment must be maintained in accordance with attached nameplate or manufacturer s approved design manual. Towing Vessel National Center of Expertise
Must be a distributor of Fire Suppression Equipment to be able to attend formal servicing training. Not receiving Safety Alerts and Safety Bulletins from Fire Suppression Manufacturers Liability: un-qualified personnel conducting maintenance on fire suppression systems. Training Issues Towing Vessel National Center of Expertise
What are the issues? C02 Cylinders are not being weighted Activation Stations not tested during servicing Alarms not being tested during servicing Operation Instructions, missing or painted over
CO2 Cylinders (not being weighed - fixed and portable) Towing Vessel National Center of Expertise
GINGE Liquid Level Indicator used Isotope (Radiation) NVIC 08-73 Alternate Means of determining the Weight of C02 in Fire Extinguishing Systems. Cancelled : 18 November 2002 Towing Vessel National Center of Expertise
Portalevel Portable Ultrasonic Liquid Level Indicator for CO2 Not authorized by the Coast Guard or the National Fire Protection Association (NFPA). Not UL approved. Towing Vessel National Center of Expertise
Activation Stations ISSUES Not tested during annual servicing Improperly using internal boxes on weather decks Not properly labeled. Towing Vessel National Center of Expertise
Audible Alarm (Typhoon) ISSUES Not tested during annual servicing Missing or painted over warning signs Towing Vessel National Center of Expertise
Operation Instructions ISSUES Missing Painted Over Towing Vessel National Center of Expertise
Warning Signs NOT POSTED Towing Vessel National Center of Expertise
Time Delay ISSUES Not Tested when serviced Less than 20 second delay Towing Vessel National Center of Expertise
Pressure Switches ISSUES Not being tested during service Located in space protected Towing Vessel National Center of Expertise