subchapter m - uscg option

Subchapter M - USCG Option

October 22, 2013

Subchapter M - USCG OptionAnnual 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 OptionPeriodic 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 OptionCompliance 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 fleetb) Within 4 years of the final rule, 50% of the fleetc) Within 5 years of the final rule, 75% of the fleetd) Within 6 years of the final rule, 100% of the fleet

Subchapter M - USCG OptionCERTIFICATE 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 OptionCERTIFICATE OF INSPECTION 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 OptionCERTIFICATE OF INSPECTION 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 OptionCERTIFICATE OF INSPECTION A COI is valid for 5 years from date of issue

A COI can be suspended or revoked at any time for non-compliance 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 OptionCERTIFICATE 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 OptionCERTIFICATE 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 OptionCERTIFICATE 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• RiversLocal conditions could cause the OCMI to prohibit operation on a route of lesser severity


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:

• Design• Scantlings• Stability• Subdivision• Propulsion• Speed• Operating modes• Maneuverability• Other characteristics


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:• Polar regions• Remote islands• Areas of extreme weather• Other remote areas where timely emergency assistance cannot

be anticipated


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.


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.


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 Option46 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 Option46 CFR PART 137 - VESSEL COMPLIANCE

SURVEYS (TSMS Option but same idea for USCG Option) A

Subchapter M - USCG Option46 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 record-keeping 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.


The Owner/Operator MUST implement procedures for reporting unsafe conditions and MUST have records of the activities conducted under this section.


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• TrainingEach element has sub-elements and all require documentation


What’s in a Health & Safety Plan?Management Leadership and Employee Involvement• 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


What’s in a Health & Safety Plan?Worksite Analysis• 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


What’s in a Health & Safety Plan?Hazard Prevention and Control• 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


What’s in a Health & Safety Plan?Hazard Prevention and Control• Bloodborne Pathogens Program• Confined Space Program• Lockout/Tagout• Emergency Evacuation Program• Required PPE including Respiratory Protection• Preventive Maintenance Schedules• Site Rules


What’s in a Health & Safety Plan?Hazard Prevention and Control• 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


What’s in a Health & Safety Plan?Training• 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.


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.



• 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



• Evaluating the associated risks• Controlling our accidental losses


What’s in a Health & Safety Plan?USCG Safety & Environmental Health Manual (336 pages)• Elements• Scope• Authority• Standards• Organization• Safety & Environmental Health Audits• Training• Pre-Mishap Plan (Emergency Response + SOP’s)


Does a Health & Safety Plan Make A Difference?


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 Option46 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.

subchapter m - uscg option

Documents

vessels coi

uscg optionannual inspection

uscg optionperiodic

valid coi

uscg option subchapter

original coi

coi inspectionocmi

temporary coi