New Eighth District Sub M Policy Letter Addresses Industry Concerns
On January 24, just as this Subchapter M-themed special issue was going to press, the Coast Guard’s Eighth District’s Inspections and Investigations Division released a policy letter addressing several towing industry concerns about Subchapter M requirements regarding pressure valves, fire control panels, day shapes, shaft tachometers, fire hose testing and visual distress signals.
Although it is an Eighth District letter rather than a national letter, the Eighth District is responsible for U.S. Coast Guard operations spanning 26 states, including the Gulf of Mexico coastline from Florida to Mexico, the adjacent offshore waters and outer continental shelf, and the inland waterways of the Mississippi, Ohio, Missouri, Illinois and Tennessee River systems.
The letter instructs Coast Guard marine inspectors to use their judgment and consider deferring enforcement on several matters on which the towing industry has raised questions.
The letter, titled D8-TVIFN 18-1, says its purpose it to “provide operational commanders with enforcement guidance when considering deficiencies or non-conformities during implementation of Subchapter M regulations throughout the Eighth Coast Guard District. It directs them to note that “although Subchapter M regulations go into effect on July 20, 2018, the overall risk profile for towing vessels has not dramatically changed.”
It says that operational commanders “may consider deferring enforcement” of the following requirements by issuing a form called a CG-835s until further guidance is issued.
The specific issues addressed include the following:
• Visual Distress Signals. The letter recognized that there are “regulatory inconsistencies on certain classes of vessels operating on rivers and lakes, bays, and sounds with regard to the requirements for visual distress signals.” The towing industry had widely questioned whether inland towing vessels, which rarely operate more than a mile from shore, need signal flares;
• Dayshapes and Navigation Lights. Many towing industry veterans questioned whether day shapes were relevant any longer;
• Pressure Vessel Maximum Allowable Working Pressure (MAWP). This rather technical guidance specifies that calculations for determining this measurement may be conducted using the National Board of Boiler and Pressure Vessel’s NB-132 Revision 8 document “or as determined by a professional engineer”;
• Existing Fire Control Panels. The letter says that operators should “seek an equivalency through their TPO or CG-ENG for fire control panels not installed in accordance with regulations”;
• Fire pump pressure testing. The letter recognizes that some hoses on towing vessels already exceed pressure requirements, and specifies that pressure need not be tested using a pitot gauge; and
• Shaft tachometers. The letter specifies that shaft tachometers, which can be expensive to install and which towing operators believe are not necessary for towing vessels, are not required by regulations. Towing vessels must only have some means of monitoring thrust.
