Vessel Inspection and Certification LCDR Christopher Hochschild USCG Training Center Yorktown Marine Inspections and Investigation School June 2020
Agenda • Flag State Jurisdiction/Marine Inspection • Alternate Compliance Program (ACP) • Plan Approval: Marine Safety Center • USCG Type Approval • UWILD
USCG as a Flag State
4 USCG as a Flag State ❑ A member state of the IMO since 1950 ❑ Signatory to SOLAS 60, 74 and 74 (Consolidated) ❑ Signatory to MARPOL ❑ Signatory to STCW ❑ Signatory to other conventions & related codes ❑ US Code & Code of Federal Regulations (CFR) ❑ The U.S. is influential in international policymaking ❑ ISPS Code ❑ Ballast Water Management
5 How does this compare for MSC Vessels? ❑ U.S. vessels operating in U.S. waters – meet applicable U.S. regulations & class rules ❑ U.S. vessels operating internationally – meet international standards, U.S. regulations & class rules ❑ MSC vessels – Meet U.S. regulations, class rules, Navy standards; may be issued a Statement of Voluntary Compliance for international standards
6 Marine Inspections Training Qualification = Training + Performance + Evaluation • Types of Training • Formal / classroom training • OJT • PQS • Advanced / specialized schools ▪ Training Locations ▪ USCG Training Center Yorktown ▪ National Centers of Expertise ▪ Units ▪ Industry / Organization Courses
7 Authority for Marine Inspections ❑ 46 U.S. Code § 3306 – Regulations ❑ Authority for inspection regulations ❑ Vessel construction, repair, machinery and appliances ❑ Lifesaving appliances and equipment ❑ Fire prevention and fire fighting ❑ Hazardous vessel stores ❑ Public vessels “exempt” – 46 USC § 2109 ❑ USCG – MSC MOA – 14 USC § 93(a)(20)
CONVENTIONAL ACP Equivalency + + =
Code of Federal Regulations Overview of Applicable Regulatory Subchapters
1 1 46 CFR - Overview ❑ Appeals – 46 CFR 1.03 ❑ Marine Casualties – 46 CFR 4.05 & 4.06 ❑ Credentialing & Manning – Subchapter B ❑ Vessel Types – Tank, Cargo, OSV, Research ❑ Vessel construction ❑ Load Lines, Stability, Machinery, Electrical ❑ Fire safety – Specific to Subchapter D, H, I ❑ Lifesaving appliances & arrangements – Sub. W ❑ National Defense Waivers – 46 CFR 6.06
1 2 46 CFR ❑ Subchapter I – Cargo & Miscellaneous Vessels Takes you to: ❑ Subchapter F – Marine Engineering ❑ Subchapter J – Electrical Engineering ❑ Subchapter W – Lifesaving Appliances & Arrangements
1 33 CFR - Overview 3 Navigation Rules – Subchapters D & E ❑ Security – 33 CFR Part 104 ( § 104.110 - exemptions) ❑ ❑ Use Force Protection plan ❑ TWIC still required for credentialed mariners Pollution – Subchapter O ❑ ❑ IOPP / Ballast Water Management – Part 151 ❑ Vessel Response Plans – Part 155 ❑ Salvage & Marine Firefighting – Part 155 Navigation Safety Regs – Part 164 ❑ National Defense Waivers – 33 CFR 19.06 ❑
1 4 49 CFR - Overview ❑ Hazardous Materials Regulations ❑ DOT Regulations ❑ Table of Hazmat – 49 CFR 172.101 ❑ IMDG Table easier to use, but check applicability for U.S. intermodal ❑ Shipping papers, marking, labeling, placarding, etc. – Part 172 ❑ Vessel carriage/stowage req’s – Part 176 ❑ Shipping container req’s – Parts 450-453
International Conventions SOLAS, MARPOL & STCW
1 6 SOLAS 74 (Cons.) - Overview ❑ History – Dates back to the Titanic sinking ❑ U.S. is signatory to 60 & 74 SOLAS ❑ 60 SOLAS: Ships built/keel laid < 25 May 1980 ❑ 74 SOLAS: Built/keel laid 25 May 1980 – 31 Aug 1984 ❑ 74 SOLAS (Cons.): Built/keel laid > 01 Sep 1984 ❑ Primary convention for construction, machinery, fire safety, navigation, lifesaving, & safety management. ❑ Parent convention for codes (e.g. ISM, ISPS, FSS, LSA, IMDG, etc.) ❑ Applies to vessels enrolled in the ACP ❑ Statements of Voluntary Compliance
1 7 MARPOL (Cons.) - Overview ❑ U.S. is signatory to Annex I, II, III, V, & VI ❑ Not signatory to Annex IV (Sewage), but USCG issues a SOVC ❑ IOPP SOVC Issued by Class or USCG ❑ Single-hull oilers exempt from double-hull requirements; however, SOVC is not issued ❑ Annex I, Ch. 8 requirements for transfers at sea are N/A (e.g. UNREP). ❑ SOPEP (Issued jointly with NTVRP/VRP)
1 8 STCW - Overview ❑ Standards of Training, Certification & Watchkeeping ❑ Applies to civilian mariners, but not military crews ❑ U.S. regulations aligned for Office is in Martinsburg, WV credentialed mariners sailing internationally
Activities Retained by the Coast Guard (ACP) • Dry-dock extensions • Enrollment into UWILD program • ****Waivers/exemptions*** • Changes of Employment • Marine Casualty Investigations • Alternate compliance with COLREGS • Approvals of Safety Equipment, materials and installation • ISSC • CSR • Excursion Permits • Permits to Proceed • Vessel Security Issues • All manning issues • Critical Area Inspection Plan (CAIP, a program used to track cracking on large oil tankers) • Ballast Water Management
2 0 Inspection for Certification (COI) ❑ COI = 5 yrs ❑ Expiration date = drop dead date ❑ Request 30 days prior to inspection
2 1 Annual & Periodic Inspections ❑ Annual: +/-3 months anniversary date ❑ Periodic: +/- 3 months before/after 2 nd or 3 rd anniversary
Alternate Compliance Program (ACP)
Authorized Vessel Types for ACP
Participating Class Society for ACP
USCG Plan Approval
2 6 Manning
USCG Type Approval
USCG Type Approval
Hull Examinations In the regs …
COI Drydock/ISE Dates on the COI…
UWILD
3 2 Resources ❑ USCG Homeport ❑ CGMIX/PSIX ❑ Office of Commercial Vessel Compliance (CG-CVC) ❑ USCG Marine Safety Center ❑ e-CFR
Q & A Contact: LCDR Christopher Hochschild Tpii School Chief Email: Christopher.p.Hochschild@uscg.mil Phone: 757-856-2844
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