Subchapter M - USCG Option
October 22, 2013
Subchapter M - USCG Option
Annual Inspection
A towing vessel choosing (or required to have) the
USCG Option MUST undergo an annual inspection within
3 months – before or after – each anniversary date
• Owner/operator contacts the OCMI for date/place
• Similar to COI Inspection but may be less detail
• COI is endorsed by OCMI after Inspection
• Deficiencies in vessel’s maintenance have to be repaired
or improved in OCMI’s timeframe
• Inspector can conduct tests and inspections as he deems
necessary
Subchapter M - USCG Option
Periodic Inspection
The vessel must also undergo a periodic inspection within 3
months – before or after – the second or third anniversary date
of the vessel’s COI. This takes the place of the annual
inspection.
• Owner/operator contacts the OCMI for date/place.
• No written application is required.
• Scope is the same as for a COI Inspection
• OCMI endorses COI after Inspection
• Deficiencies in vessel’s maintenance have to be repaired or
improved in OCMI’s timeframe
• Inspector can conduct tests and inspections as he deems
necessary
Subchapter M - USCG Option
Compliance with the USCG Option
Owner/Operators with more than one towing vessel required
to have a COI and choosing the USCG Option, MUST ensure
that each vessel under their ownership or control is issued a
valid COI according to this schedule:
a) Within 3 years of the final rule, 25% of the fleet
b) Within 4 years of the final rule, 50% of the fleet
c) Within 5 years of the final rule, 75% of the fleet
d) Within 6 years of the final rule, 100% of the fleet
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
A towing MAY NOT be operated without having onboard a
valid COI issued by the USCG.
Each towing vessel certificated under these provisions
MUST be in FULL compliance with the terms of the COI
A temporary COI may be issued to prevent delays while
waiting for the regular COI.
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
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A COI describes the following:
Vessel
Route(s) it may travel
Minimum manning requirements
Minimum safety equipment carried
Horsepower
Other information pertinent to
the vessel’s operations as
determined by the OCMI
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
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Obtaining a COI
Make an application to the OCMI of the marine inspection
zone in which the towing vessel is principally operated or in
which management offices are maintained
Complete form CG-3752 “Application for Inspection of a US
vessel”
Provide objective evidence that the vessel’s structure and
stability and essential systems comply with applicable
requirements of Sub M for intended route and service. This
evidence can be an approved third party report.
Provide vessel specific information
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
A COI is valid for 5 years from date of issue
A COI can be suspended or revoked at any time for noncompliance with the requirements of Sub M
The original COI MUST be framed under glass and posted in
a conspicuous place on the vessel.
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
The area of operation for each towing vessel and any
operational limits is determined by the OCMI and recorded on
the COI. The major headings for each area of operation (Route)
are:
• Oceans
• Coastwise
• Limited Coastwise
• Great Lakes
• Lakes, Bays and Sounds
• Rivers
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
Further limitations imposed or extensions granted are
described by reference to:
• Bodies of Water
• Geographical Points
• Distances from Geographical Points
• Distances from Land
• Depths of Channel
• Seasonal Limitations
• Similar Factors as determined by the OCMI
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
Operation of the vessel on a route of lesser severity than
those specifically described or designated on the COI is
permitted unless expressly prohibited on the COI. The general
order of severity of routes is:
• Oceans
• Coastwise
• Limited Coastwise
• Lakes, Bays and Sounds
• Rivers
Local conditions could cause the OCMI to prohibit operation on
a route of lesser severity
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
When designating a permitted route or imposing operational
limits on a towing vessel, the OCMI may consider:
• The route specific requirements of Sub M
• The performance capabilities of the vessel based on:
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Design
Scantlings
Stability
Subdivision
Propulsion
Speed
Operating modes
Maneuverability
Other characteristics
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
When designating a permitted route or imposing operational
limits on a towing vessel, the OCMI may consider:
• The suitability of the vessel for nighttime operations and use
in all weather conditions
• Vessel operations in globally remote areas or severe
environments not covered in this SubChapter. Such areas
may include, but are not limited to:
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Polar regions
Remote islands
Areas of extreme weather
Other remote areas where timely emergency assistance cannot
be anticipated
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
Permit to Proceed
A vessel may need permission to proceed to another port for
repairs if it is no longer in compliance with its COI.
The vessel may proceed to another port if:
• In the judgment of the Owner/Operator or Master the trip can
be completed safely
• The owner/operator MUST notify the OCMI in whose zone
the non-compliance occurs or is discovered before the vessel
proceeds and any other OCMI zones through which the
vessel will pass.
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
Permit to Proceed
A vessel may need permission to proceed to another port for
repairs if it is no longer in compliance with its COI.
The vessel may proceed to another port if:
• The vessel will not engage in towing unless the OCMI deems
it safe to do so
• The OCMI may require inspection of the vessel by a USCG
Marine Inspector or examination by an approved third party
prior to the vessel proceeding.
Subchapter M - USCG Option
CERTIFICATE OF INSPECTION
PERMIT TO CARRY AN EXCURSION PARTY
A towing vessel MUST obtain approval to engage in an
excursion prior to carrying a greater number of persons than
permitted by the COI or a temporary extension or alteration of
the area of operation.
The vessel may not engage in towing during the excursion
unless the OCMI deems it safe to do so.
The OCMI may require the inspection of the vessel by a
USCG Marine Inspector or examination by an approved third
party.
Subchapter M - USCG Option
46 CFR PART 137 - VESSEL COMPLIANCE
SURVEYS (TSMS Option but same idea for USCG Option)
A survey of the towing vessel must determine that the item or
system
• Functions as designed
• Is free of defects or modifications that reduce its
effectiveness
• Is suitable for the service intended
• Functions safely in a manner
consistent for the vessel type,
service and route
Subchapter M - USCG Option
46 CFR PART 137 - VESSEL COMPLIANCE
SURVEYS (TSMS Option but same idea for USCG Option)
A
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
No later than three years after the effective date of the
final rule, the Owner/Operator MUST implement a
health and safety plan. The plan must include recordkeeping procedures. Records must document
compliance with this part.
The Owner/Operator and Master MUST ensure that
all persons onboard a towing vessel comply with the
health and safety plan.
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
The Owner/Operator MUST implement procedures
for reporting unsafe conditions and MUST have
records of the activities conducted under this section.
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
According to OSHA, the management system
contains four basic elements:
• Management Leadership and
Employee Involvement
• Worksite Analysis
• Hazard Prevention and Control
• Training
Each element has sub-elements and all require
documentation
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
Management Leadership and Employee Involvement
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Worksite Policy
Current year’s goals, objectives, action plans and program
evaluation
Job Descriptions that include H & S responsibilities
Performance Evaluations
Budget showing money allocated to H & S
Contractor bidding sheets with their H & S records
Orientation outline for all visitors/contractors
Evidence of employee involvement
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
Worksite Analysis
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Results of baseline S & H surveys w/hazard corrections
Forms used to change analyses, inc S & H considerations
for purchasing new equipment, chemicals or materials
JHA’s
Employee reports of hazards
Site S & H inspection results w/corrections
Accident investigation reports w/hazard corrections
Trend Analysis results
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
Hazard Prevention and Control
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Four step disciplinary system for violation of S & H rules
Use of outside professionals to analyze site for S & H
Employee Medical records
• Ability of employee to perform jobs
• Job limitations or accommodations needed
• Length of time for limitations
Hazard Communication Program
Hearing Conservation
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
Hazard Prevention and Control
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Bloodborne Pathogens Program
Confined Space Program
Lockout/Tagout
Emergency Evacuation Program
Required PPE including Respiratory Protection
Preventive Maintenance Schedules
Site Rules
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
Hazard Prevention and Control
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Written programs mandated by federal agencies
Maintenance records
Emergency drill procedures and critiques
Health surveillance and monitoring records
Reports and investigations of near misses, first aid and
incidents
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
Training
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New crew orientation
Weekly safety meetings, training and drills
Maintenance of employee training records
List of yearly training topics with trainer and his
qualifications
Yearly training class schedule with attendance lists
Individual training records with evidence of subject
mastery.
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
USCG Safety & Environmental Health Manual (336 pages)
• Vessel Safety Program Elements - Section 8
• POLICY: Safety is an integral part of all USCG
operations. All members must commit to personal
responsibility to safeguard themselves, fellow crew
members, and the property entrusted to their care. The
leadership and responsibility for all safety programs
must originate from senior leadership and follow the
chain of command to each individual in the command.
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
USCG Safety & Environmental Health Manual (336 pages)
• Vessel Safety Program Elements - Section 8
• GOAL: The goal of the Vessel Safety Program is to
improve safety, enhance mission effectiveness and
increase the operational readiness of all USCG floating
units by:
• Identifying the loss exposures that endanger our
people, platforms, equipment and mission readiness
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
USCG Safety & Environmental Health Manual (336 pages)
• Evaluating the associated risks
• Controlling our accidental losses
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
What’s in a Health & Safety Plan?
USCG Safety & Environmental Health Manual (336 pages)
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Elements
• Scope
• Authority
• Standards
• Organization
• Safety & Environmental Health Audits
• Training
• Pre-Mishap Plan (Emergency Response + SOP’s)
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
Does a Health & Safety Plan Make A Difference?
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
Does a Health & Safety Plan Make A Difference?
#1 - What Return on Investment can
S&H programs provide?
#2 - How can safety & health become a
part of the way our business runs?
Improved employee morale,
Decreased lost time,
Fewer workplace injuries and illnesses,
Lower insurance costs, and
Safety culture adoption.
Combine performance standards with
S&H standards,
Talk the talk and walk the walk,
Top down support, and
Bottom up implementation.
Subchapter M - USCG Option
46 CFR PART 140 – HEALTH & SAFETY PLAN
#3 - What indicators tell me if I'm
getting weaker or stronger?
#4 - What practices are best for
assuring lasting success?
Statistical reports,
Opinion surveys,
Risk analysis,
Periodic inspections,
Process improvement initiatives.
Obtain management buy-in.
Build trust.
Conduct self-assessments.
Develop a site safety vision.
Develop a system of accountability and
measures.
Implement recognition and rewards.
Provide awareness training.
Implement process changes.
Continually measure, communicate
results and celebrate successes.