PROCEEDINGS Winter 2018 Vol. 75, Number 3 Navigating Compliance Addressing Safety Subchapter M and Assessments Towing Vessel Stability | 37 An often overlooked but The Towing Vessel National Flexibility and Compliance | critical safety consideration 6 Center of Expertise | Your 22 Balancing the need for both by Captain William J. Sullivan navigator for Subchapter M in the wake of Subchapter M by CDR Andrew Bender by Jill Bessetti Coast Guard Academy 40 Graduate Tackles Credentialing Today’s Towing Vessel Inspections Real-World Issues 9 Towing Industry for 26 Training | Past, present, and by Ensign Erin Morgan Tomorrow future by Michael C. Lewis and by CWO4 Rob Birdwell and Keeping Towing Vessels LT Katherine Cameron LCDR Christian Barger 43 on Course | Coast Guard inland cutters help keep The Role and Importance of Assessing Today’s Bridge commerce flowing 15 the Towing Safety Advisory 31 Officers | NSAP: A powerful by Walter T. Ham IV Committee tool for dynamic evaluation by Eric J. Johansson by Keith Fawcett A Voyage Fraught with 48 Challenges | Learning Subchapter M | Taking from the grounding of 18 the long view the MODU Kulluk by Jennifer Carpenter and by Keith Fawcett and Caitlyn Stewart Captain Marc Dial A tugboat approaches the Coast Guard Cutter James near Mayport, Florida, on March 30, 2017. James is the Coast Guard’s fth national security cutter, the Coast Guard’s largest and most technically advanced class of cutter, with robust capabilities for maritime homeland security, law enforcement and national defense missions. Coast Guard photo by Petty Ocer 1st Class Melissa Leake Editorial Team Samantha L. Quigley Executive Editor Antonio E. Balza Managing Editor Leslie C. Goodwin On Deck Graphic Designer Proceedings is published three times a year in Assistant Commandant’s Chemical of the Quarter the interest of safety at sea under the auspices 4 Perspective Understanding Methane of the Marine Safety & Security Council. by Rear Admiral John P. Nadeau 62 (Natural Gas) Special permission for republication, either by LT Jake Lobb in whole or in part, except for copyrighted Champion’s Point of View material, is not required, provided credit is given to Proceedings. 4 by CAPT Jennifer F. Williams Nautical Queries Engineering The articles contained in Proceedings Historical Snapshot 63 are submitted by diverse public and pri- vate interests in the maritime community Remembering the as a means to promote maritime safety 54 Andrea Doria | Confusion Deck and security. The views expressed by the leads to catastrophe 65 authors do not necessarily represent those by LCDR Kent G. Sieg of the U.S. Coast Guard or the Depart- ment of Homeland Security or represent ocial policy. Graphics provided by the Coast Guard and its licensors, unless otherwise indicated. Editorial Contact Email: [email protected] Mail Commandant (CG-5PS) ATTN: Editor, Proceedings Magazine U.S. Coast Guard Stop 7318 The Andrea Doria. Coast Guard photo 2703 Martin Luther King Jr. Ave. S.E. Washington, DC 20593-7318 On the Cover: A milestone nearly Web: www.dco.uscg.mil/proceedings 15 years in the making, April 20, Phone: (202) 372-2316 2018, marked the issuance of the first tugboat and towboat Subscription Requests certificates of inspection under Subchapter M. Published in the Proceedings is free of charge and published in April, August, and December. Federal Register on June 20, 2016, 46 CFR Subchapter M established Subscriptions: new minimum safety standards for www.dco.uscg.mil/proceedings existing towing and tug vessels, like the one on this issue’s cover. Some have said Subchapter M, as it’s frequently called, is the most important rulemaking ever to affect the tugboat and towboat industry. Repina Valeriya | Shutterstock.com Admiral Karl L. Schultz Commandant U.S. Coast Guard Assistant The Marine Safety Commandant’s & Security Council of the United States Coast Guard Perspective by REAR ADMIRAL JOHN P. NADEAU Rear Admiral Steven J. Andersen Assistant Commandant for Prevention Policy Judge Advocate General U.S. Coast Guard & Chief Counsel Chairman Rear Admiral Melissa Bert Director of Governmental and Public Affairs Marine safety is one of the Coast systems, lifesaving equipment, and Member Guard’s 11 statutory missions, and fire detection and extinguishing sys- commercial vessel inspections are tems. Furthermore, other aspects of Rear Admiral Thomas G. Allan Assistant Commandant for an integral part of the marine safety commercial vessels are inspected Resources, Chief Financial Officer program. Coast Guard marine inspec- to ensure they meet the required Member tors examine structural integrity, safety and environmental protection Rear Admiral John P. Nadeau inspect engineering and navigation standards. Assistant Commandant for Prevention Policy Member Captain Jennifer F. Williams Director of Inspections and Compliance Member Mr. Jeffrey G. Lantz Director of Commercial Champion’s Regulations and Standards Member Point of View Mr. Michael D. Emerson Director of Marine Transportation Systems Member by CAPT JENNIFER F. WILLIAMS Rear Admiral Anthony J. Vogt Assistant Commandant Director, Inspections and Compliance for Response Policy U.S. Coast Guard Member Ms. Dana S. Tulis Director of Incident Management and Preparedness Policy I am pleased to champion this edi- States, the development of the regula- Member tion of Proceedings, which highlights tions, associated policies, and training Mr. William R. Grawe recent regulatory changes introduced has been a huge undertaking executed Director of National Pollution in Subchapter M, the Inspection of over the course of more than 15 years. Funds Center Towing Vessels. With such a large The work leading up to the devel- Member number of commercial towing ves- opment of regulations is underscored Mr. Michael W. Mumbach sels operating throughout the United by the Coast Guard personnel and Executive Secretary 4 Proceedings Winter 2018 For decades, the majority of commercial tow- their unique risks. Both options enable the vessel ing vessels were not required to undergo manda- to receive a certificate of inspection from the Coast tory Coast Guard safety inspections. That changed Guard. in June 2016, with the publication of Subchapter M, A good safety management system is scalable, or the Inspection of Towing Vessels: Final Rule. Today, dynamic, and customized to match the unique needs nearly 6,000 commercial towing vessels are subject and risks of the individual vessel and operator. It to inspection requirements and the total number of reinforces a healthy safety culture and promotes an U.S. flag vessels inspected by the Coast Guard has environment where all employees share the responsi- doubled. bility for safety. In addition, an effective safety man- Subchapter M is a groundbreaking regulation agement system facilitates continuous improvement in that it allows towing vessel operators to choose and optimizes safety performance. I am a strong between the Coast Guard option or a Towing Safety advocate for safety management systems, and it is Management System (TSMS) option. The Coast my hope that the majority of towing vessel operators Guard option is a traditional Coast Guard inspec- elect to use the TSMS option. tion, where a Coast Guard marine inspector visits I want to extend my sincere thanks to each of the vessel during its dry-dock period and also per- the authors, editors, and Champion for this edition forms annual inspections. The TSMS option pro- of Proceedings. I hope you find the information in vides vessel operators greater flexibility by allowing the pages that follow useful, and I look forward to them to work directly with an approved third party working with all stakeholders to improve safety and organization and develop a TSMS that addresses security. maritime industry’s anticipation of implementing of the new workload, operational impacts, or the these regulations There is a lot of uncertainty about dynamics between vessel operators and Coast how the new standards will be applied, or how they Guard—or the TPOs—until more vessels complete will impact operations for nearly 6,000 towing ves- their initial inspection for certification and a rhythm sels whose operators, crews, and newly established is developed. But, there is reason for optimism. More third party organizations (TPO) have had little to than 50 percent of the towing vessel fleet is poised to no interaction with Coast Guard marine inspec- transition into the inspected fleet with ease because tors. The Coast Guard shares the same concerns as it they have either participated in the Responsible impacts work load, training, and visibility of vessels Carrier Program, or have adopted International that choose the Towing Safety Management System Safety Management Systems. Regardless of option, I option—managed by third party organizations— hope that this issue of Proceedings will shed some light over the Coast Guard option. Since the publishing on different aspects of the new inspection require- of the final rule in 2016, the Coast Guard, Towing ments, and introduce you to several subject matter Vessel Safety Advisory Committee, American experts in the field. Waterways Operators, towing vessel operators, and I would like to take this opportunity to extend third party organizations have discussed many of thanks to my staff for their help in coordinating this these concerns. We have developed guides, policies, edition, and to all the authors who have taken the and frequently asked questions to help address these time to contribute articles. Your efforts are instru- issues. mental to highlighting towing vessel safety, and the Unfortunately, we will not truly know the impact roles the regulators and the regulated play. Winter 2018 Proceedings 5 Navigating Subchapter M The Towing Vessel National Center of Expertise Your navigator for Subchapter M by CDR ANDREW BENDER Supervisor U.S. Coast Guard Towing Vessel National Center of Expertise fter navigating a 15-year regulatory process, the The program continued to take shape with the open- towing vessel industry1 has officially embarked ing of the Towing Vessel National Center of Expertise on its voyage as an inspected fleet with the issu- (TVNCOE) in Paducah, Kentucky.