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Towing vessel NATIONAL Center of Expertise. Towing Vessel National Center of Expertise. STAFF. Active Duty CDR Pat Nelson LCDR Jaime Salinas LT Paris Stratton Civilian Roy Murphy Mike Kelly Steven Douglass Dave Phillips. Vision

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towing vessel national center of expertise
Towing vessel NATIONAL Center of Expertise

Towing Vessel National Center of Expertise

slide2

Towing Vessel National Center of Expertise

Towing Vessel National Center of Expertise

staff
STAFF

Active Duty

CDR Pat Nelson

LCDR Jaime Salinas

LT Paris Stratton

Civilian

Roy Murphy

Mike Kelly

Steven Douglass

Dave Phillips

Towing Vessel National Center of Expertise

slide5

Vision

Be the Coast Guard's forward thinking component in the towing industry to keep all TVBP stakeholders well-prepared to handle current and future needs

Mission 

  • Serve as in-house consultants
  • Provide technical advice to both industry and the Coast Guard
  • Increase and maintain the Coast Guard’s collective competency

Towing Vessel National Center of Expertise

professional objectives
Professional Objectives

Towing Vessel National Center of Expertise

slide7

TVNCOE

NEW

www.uscg.mil/tvncoe

towing vessel bridging program
Program elements & expectationsTowing vessel bridging program

Towing Vessel National Center of Expertise

purpose
Purpose

Bridge the gap – Ease the transition

Towing Vessel National Center of Expertise

goals
Goals

Towing Vessel National Center of Expertise

3 phases
3 Phases

Law Enforcement Boardings & Surge Operations

Towing Vessel National Center of Expertise

utv fleet of responsibility 5571 industry initiated exams 5908 prioritized exams remaining 407
UTV Fleet of Responsibility = 5571Industry Initiated Exams = 5908Prioritized Exams Remaining = 407

100 89 27

239 329 34

286 257 87

402 345 39

3733

3999

144

164 184 20

287 317 15

295 314 41

65 74 0

timeline
Timeline

COI

03/15 Final Rule (?)

2011 NPRM

2004 CG Auth Act

Implementation

2009 TVBP

Steamboat inspections 1800’s

Towing Vessel National Center of Expertise

slide14

Compliance Phase-in

YR

2

YR

8

YR

9

YR

10

YR

0

YR

3

YR

4

YR

5

YR

6

YR

11

Towing Vessel National Center of Expertise

policies guidance
Problems & SolutionsPolicies & guidance

Towing Vessel National Center of Expertise

lesson objectives
Lesson Objectives
  • DETERMINE current policies and guidance
  • STATEthe Exemptions, Appeals and Equivalencies procedures.
  • STATE sources to obtain current policies and guidance.

Towing Vessel National Center of Expertise

frequently asked questions
Frequently Asked Questions

PORTABLE FIRE EXTINGUISHER INSPECTION/MAINTAINANCE

Q. Where can I find information on maintenance and inspections required for portable fire extinguishers?

Ans. National Fire Protection Association (NFPA) 10 Standard for Portable Fire Extinguishers.

You may obtain a copy of NFPA 10 through the

National Fire Protection Association.

TVNCOE

Towing Vessel National Center of Expertise

fixed co2 systems
Fixed CO2 Systems

Issue

Policy Letter 10-06

Allows designation of “Excess Equipment” for certain circumstances.

  • Some systems are not installed IAW 46 CFR 76.15
  • Examples:
    • Bottles over 300lbs capacity located inside space being protected
    • Inadequate amount of CO2 for space

Towing Vessel National Center of Expertise

slide19

TVNCOE

NEW

www.uscg.mil/tvncoe

exemptions appeals equivalencies
AwarenessExemptions, appeals & equivalencies

Towing Vessel National Center of Expertise

flexibility in the law
Flexibility in the Law

Towing Vessel National Center of Expertise

equivalencies
Equivalencies
    • 46 CFR 24.15-1
  • Granted by COMDT
  • Substitution that is at least as effective as that specified in regulation.
  • Examples of equivalencies granted so far:
    • Fuel shut off valves
    • NICET Level IV Technicians

Towing Vessel National Center of Expertise

exemption
Exemption
  • Only for a specific regulation
  • Most can be granted by COTP
  • If denied, owner/operator has right to appeal
  • Examples:
    • EPIRB - 46 CFR 25.26-60(b) Dist Cmdr exemption
    • Fire Protection - 46 CFR 27.100(b)(4) & 27.100(c)
    • Navigation Safety - 33 CFR 164.01-(b)(4)

Towing Vessel National Center of Expertise

appeals
Appeals
    • References
      • 46 CFR 24.01-7 (will direct the reader to 1.03)
      • 46 CFR 1.03
      • 46 CFR 1.01
  • 30-day time limit
  • Written request
  • Description of decision/action & why it should be revised

Towing Vessel National Center of Expertise

rules of thumb for equivalents exemptions and appeals
Rules of Thumb for Equivalents, Exemptions, and Appeals
  • Formal written requests from owner/operators
  • Must provide justification for request
  • Submitted thru Chain of Command (via cognizant OCMI/COTP)
  • COMDT is the highest and final authority on decisions/actions
  • See process guide at TVNCOE website for help (template letters/memos available)

TVNCOE

Towing Vessel National Center of Expertise

questions
Questions?

Towing Vessel National Center of Expertise