Sub M — Implementation 1 Sub M

Sub M - Implementation 1

Sub M - Implementation § Compliance Timeline § Highlights of What Changed from NPRM § Compliance Options

UTV Fleet of Responsibility 5, 719 91 292 163 230 3, 905 421 270 282 65

Compliance Timeline YR 0 YR 1 & 2 30 -day Effective Date • TPO requirements • TPO approvals • Stability, watertight, & weather-tight 20 July 2016 YR 3 YR 4 YR 5 YR 6 Health and Safety Plan After First Year 22 July 2019 Keel Laid Date New Vessel 20 Jul 2017 YR 7 - 10 YR 11 Deferred Equipment • Pilothouse alerter system • Towing machinery (i. e. winches, bitts, guards etc. ) • Comply with Sub M - 20 July 2018 • TSMS Certificate issued by approved TPO 6 months prior to COI Issue: starting 20 Feb 2018 4

Sub M – What Changed from the NPRM See Table 4 in final rule that summarizes the changes. Ø Requirement to minimize distractions – (cell phones, laptops, etc. ) Ø User Fee – default $1, 030 Ø Objective Evidence for Stability & Drydock to receive initial COI Ø Require owners or operators to maintain watertight integrity & stability. Ø Letter of designation for PIC of fuel transfer – not applicable to inspected vessels. Ø Removed: § Remote Engine Shutdown requirement § Automatic external defibrillators and train crewmembers in their use. § New Electrical system requirements for existing towing vessels § Clarified requirements for independent means of propulsion, steering and related controls on towing vessels moving tank barges – applies to new vessels only

Sub M – Compliance Options for certification of a towing vessel: 1. Coast Guard Option 2. TSMS Option: a. b. External Survey Program Internal Survey Program 3. ISM option – Recognized Classification Society (External/Internal)

Coast Guard Will: • Issue COIs – set routes & manning • Perform annual inspection • Attend drydock & internal structural exams • Issue deficiencies • Oversee Repairs • Conduct Drills • New Construction/Major modifications oversight • Plan review & P/E oversight (OCMI & MSC) • Respond to Marine Casualties – issue deficiencies/ enforcement if appropriate Towing Company Will: • Schedule inspection/drydock/ISE with local OCMI • Make vessel available for inspection

TSMS Survey Programs External Surveys are conducted by TPO, which can be a Classification Society. Internal Surveys are conducted by trained personnel with a direct affiliation to the vessel, owner or managing operator. Internal Surveys, or examinations, can be completed in stages over time. Mix of two (internal topsides, external drydocking, etc) – flexibility to use TPO or Class Society in lieu of internal company resources or contracted surveyors.

TSMS Options within the Option Required for all TSMS Options Company (Management) Vessel • External TSMS audit every 5 years by TPO • External mid-period TSMS audit by TPO • Annual internal management TSMS audits • External TSMS audit every 5 years by TPO • CG inspection for certification every 5 years • Credit dry dock(s) and ISE(s) * * Dry docks/ISEs under the internal survey program can be a continuous event scheduled over time 137. 315(c) Company choice (Options) – pick one. . . or. . . more. . . External Survey Program Internal Survey Program • Annual vessel survey by a TPO • Survey is a single event within 3 months of the COI date • External drydock exam • Annual vessel survey by company* • Survey can be a continuous event scheduled over time (up to 1 year ) • Internal drydock exams over time Note: A CG accepted existing SMS or a fully compliant ISM SMS can be used to meet TSMS requirements 138. 225

Approved Third Parties Will: • Review/Approve/Oversee TSMS/ISM • Issue TSMS Certificate – valid for 5 yrs • Plan review & P/E oversight • Survey/Audit • Mid-period & TSMS issuance Mgmt Audit • Annual Internal Mgmt Audit • Vessel Audit once every 5 yrs • Dry-dock/ISE & Annual Vessel Survey • New Construction/Major Mod Survey • Issue non-conformities & clear deficiencies issued by CG • Document compliance/Submit required reports/Maintain records Towing Company Will: • Develop/Implement SMS • Document compliance/Submit required reports/Maintain records Coast Guard Will: • Issue COIs – set routes & manning • Review objective evidence/report(s) at COI • Targeted exam – May attend annual survey, dry-dock or major non-conformities • Respond to Marine Casualties – issue deficiencies/enforcement if appropriate • Direct vessel and/or company audits as needed • NCOE review TPO reports. • Appeals

Approved Third Parties Will: • Review/Approve/Oversee TSMS • Issue TSMS Certificate – valid for 5 yrs • Plan review & P/E oversight* • Audit Companies & Vessels • Mid-period & TSMS issuance Mgmt Audit • Vessel Audit once every 5 yrs • Oversee Company Internal Survey Program • Issue non-conformities & clear deficiencies issued by CG • Document compliance/Submit required reports/Maintain records Towing Company Will: • Develop/Implement SMS • Survey /Audit • Dry-dock/ISE & Annual Vessel Survey • Annual internal management TSMS audits • Document compliance/Submit required reports/Maintain records Coast Guard Will: • Same as TSMS External Survey Option

Initial COI 6 Months Before COI Inspection (If utilizing TSMS) If TSMS & company complies w/requirements, TPO audits management & vessel*. TPO issues company TSMS Certificate. Company maintains list of vessels under TSMS Certificate. 3 Months Before COI Inspection Company schedules initial COI inspection with OCMI. 30 Days Before COI Inspection Company submits Application for Inspection to OCMI. TSMS Vessels also submit Objective evidence to OCMI per 136. 210 and 137. 202. Initial COI Inspection Conducted by U. S. Coast Guard and a COI is issued. *Vessels external audit may be conducted 6 months after the COI if the vessel has been owned for less than 6 months

Benefits of a TSMS • Flexibility • Can be scaled for company size/type • Rolling surveys • Don’t have to schedule days/weeks in advance & potentially take vessel out of service • TPO or Company role in drydocks/ISE/new construction/major modifications • Accountability • Establishes responsibility • Continuous Compliance • Consistency • Clear, well defined procedures/roles • Documentation Management Review Checking & Corrective Action Policy Planning Implementation & Action

Sub M – Third Party Organization (TPO) Third Party Will: Ø Submit application to be an approved TPO Auditor and/or Surveyor Ø Notify Surveyor/Auditor removal of employment CG Towing Vessel NCOE Will: Ø Approve 3 rd Parties Ø Review/Approve 3 rd Party Auditor/Surveyor Ø Maintain list of approved TPOs Ø Audit TPO once every 5 yrs Ø Make available to the CG all required oversight elements Ø Attend at least one External Management Audit for each TPO once every 5 yrs. Ø Notify CG prior to conducting a 3 rd Party “External” Management (Company) and Vessel Audits Ø Coordinate & advise on targeting/ performing oversight exams Ø Submit External Audit results to CG Ø Suspend/Terminate TPO – appeal to CG-CVC Ø Review Audit reports & place in MISLE Ø Notify local OCMI of major non-conformities

Sub M – Existing Vessels Ø Ø Electrical requirements for existing vessels are minimal Major Modifications Owners/operators must maintain watertight integrity & stability Use of doublers will likely be accepted on certain routes & services – more guidance to follow Ø Sub M lifesaving requirements above Sub C Flares Water light on life-ring on rivers Skiff allowed in Lieu of Rigged Inflatable inside three miles § § § Ø Corrected dates for § § § New installations of pressure vessels on existing vessels - July 20, 2018 Trigger date for alterations or modifications that results in major conversion has been corrected to July 20, 2017. New installation that is not a ''replacement in kind'' - this requirement starting July 20, 2018

Sub M – Moving Forward Ø Develop guidance – § § NVICs on TPO guide, compliance & implementation MSM Vol III manning – should be published in Federal Register in the next few days Ø Towing Vessel Safety Advisory Committee – task statements Ø Towing Vessel National Center of Expertise

Questions Capt Kevin Oditt USCG Eighth District Chief of Prevention 3/18/2018 Unclassified