Towing Vessel Bridging Program — Phase 2

On May 3, the U.S. Coast Guard released an update on its Coast Guard Towing Vessel Bridging Program.

Phase 1 of the Bridging Program began in June 2009. The purpose of the program was to prepare the towing industry for the impending inspection regulations contained in Subchapter M, and at the same time familiarize Coast Guard personnel with towing vessels and their operations. The Coast Guard estimates there are a total of approximately 5,800 towing vessels. Since the beginning of the first phase of the Bridging Program, the Coast Guard has conducted 4,200 industry- initiated examinations and issued 3,200 decals to towing vessels.

It is important to note that these are examinations being conducted, not inspections. The towing vessels being examined are currently “uninspected vessels.” The examination is to verify compliance with existing regulations, which apply to uninspected towing vessels. Once Subchapter M is finalized there will be many more regulatory requirements for these towing vessels, and they will be inspected for certification and receive a certificate of inspection, not an examination sticker.

According to the Coast Guard, Phase 2 will commence on July 1, 2012. During phase 1 the Coast Guard relied upon industry to volunteer to have their vessels examined. Phase 2, while still allowing industry-initiated exams, will also begin prioritized exams and underway law enforcement boardings and surge operations. High priority vessels under Phase 2 are those vessels owned or operated by companies that have not participated in Phase 1. Low priority vessels are those vessels owned or operated by companies actively participating in the Bridging Program but not all of the company’s vessels have been examined. Non-priority vessels are vessels owned or operated by a company, which has participated in the bridging program and has already been examined.

Prioritized exams will be the same scope as industry initiated exams but will be at the convenience of the Coast Guard, not the company. Deficiency reports will be issued during prioritized exams and the deficiencies will have to be resolved within the allotted time frame in order to avoid civil penalty. Notice of Violations may be issued for noncompliance during law enforcement boardings. Coast Guard’s Phase 2 memorandum explains that while deficiencies found during industry initiated exams were not available to the public, deficiencies found during Phase 2 prioritized exams will be entered into the PSIX website and will be available to viewing by the public.

Even though Subchapter M seems far of at times the Coast Guard is moving forward with their program to prepare the industry for what the future has in store. The Phase 2 memo explains the “risk” associated with not achieving the goal of the Bridging Program is that, “…companies and their vessels may not be prepared for an environment where they must have a Certificate of Inspection (COI) to operate their vessel(s).” Phase 2 will certainly bring the industry closer to that reality.

For more information, visit Maritime Compliance International.

About the author

Kevin Gilheany

Kevin Gilheany is a marine consultant and owner of Maritime Compliance International in New Orleans. He works with companies to help increase profitability through improved compliance and management systems. Gilheany is a retired U.S. Coast Guard marine inspector, certified marine surveyor and auditor, and crew endurance management expert. He has also provided contract training to the U.S. Coast Guard, was an adjunct instructor of maritime security at Tulane University’s Homeland Security Studies Program, and has contributed to marine industry publications. He can be reached at kgilheany@marcomint.com or www.maritimecomplianceinternational.com.

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