IMX Panel Examines Cost, Standards For Drydock Hull Inspections
The towing industry is busy developing its own standards for the drydock hull and internal structural inspection requirement of Subchapter M, while awaiting further Coast Guard guidance. That situation was the focus of the second presentation on Subchapter M implementation at this year’s Inland Marine Expo, which was held virtually. Chris Parsonage, executive director and founder of the Towing Vessel Inspection Bureau, said the drydock inspections could be the most “expensive and painful” part of Subchapter M compliance.
Parsonage moderated the discussion, titled “Sub M Part 2: Cost Considerations and General Q&A with Shipyard Perspectives.” Vessels that have earned their certificate of inspection (COI) have five years from the date of issuance to conduct a structural exam (2-1/2 years if they operate in saltwater), and Parsonage said the session would address unanswered questions regarding how such surveys should be conducted.
Current regulations leave a lot of room for interpretation—by both the Coast Guard and third-party organizations—about exactly how such exams should be conducted. For companies that have towing safety management systems (TSMS), it’s important for them to specify (and comply with) their own measurable standards, especially since, Parsonage said, ABS hull standards alone could allow some vessels to operate with plate and equipment “where you don’t want to be.”
Caitlyn Stewart, senior director-regulatory affairs for The American Waterways Operators, gave a brief history of the regulations on hull inspection. The founding guidance document is the Coast Guard’s NVIC 7-68 (1968), Notes on Inspection and Repair of Steel Hulls.In 2012, the year after the Subchapter M proposed rule was published, AWO set up a joint subcommittee with the Coast Guard to study the ways in which industry practices regarding hull inspection might need to be adjusted in the light of Subchapter M. That subcommittee produced a report in 2014 that was studied by the Towing Safety Advisory Committee (at the Coast Guard’s request), which made some recommendations of its own before endorsing it. The Subchapter M final rule was published in 2016, but the Coast Guard has not yet published any updated hull inspection guidance.
Last summer, an AWO working group began developing (with the Coast Guard’s agreement) a set of voluntary industry best practices regarding hull and structural inspection and repair. It included AWO members operating on both the inland waterways and saltwater environments and members of TPOs. The working group published a set of guiding principles, including that companies should establish procedures for regularly examining hull condition; where repairs are required, they should consider the probability and consequences of hull failure and do a cost-benefit analysis of alternatives. The Coast Guard is currently reviewing this best-practices document.
The inland fleet is composed of long-lived vessels operating in a fresh-water environment with no significant history of hull failure, Stewart noted. Key issues that emerged during the development of this document included the use of doubler plates for repairs, repair of internal structural members, testing of repairs, welding standards, monitoring and managing of water in void spaces and repair of set-ins. The document has since been revised after feedback from the Coast Guard and is awaiting further response. The Coast Guard has been working on a document updating NVIC 7-698’s guidance, Stewart said.
Who Must Be Present?
Capt. Tracy Phillips, chief of prevention for the Eighth Coast Guard District, then outlined hull inspection procedures under the different options allowed by Subchapter M. Vessels that are choosing the Coast Guard inspection option must have the officer in charge of marine inspection (OCMI) aboard for the hull inspection. It’s strongly recommended that companies have their own written set of procedures. For those using a TPO, an external option, the TPO representative must be aboard during a hull inspection. For those using an internal option, neither the TPO nor the Coast Guard is required to be present (although they may be), and the entire report does not need to be sent to the OCMI, but any condition discovered during the inspection affecting safety must be communicated to the Coast Guard. Examples would include severe hull wastage, a hull breach, etc. Phillips recognized that additional Coast Guard guidance on what constituted an “unsafe condition” is necessary, and she asked for industry feedback.
“Replacements in kind”—that is, replacements designed to restore something to its original condition—do not need to be individually reported, although all such work does need to be documented for when the COI is renewed.
A change in the purpose of a space, change in weight of the vessel or change in equipment needs to be documented. Design changes need to be certified either by a classification society specialist or the Coast Guard. The documentation will be very important when the vessel renews its COI.
A “major conversion” that significantly changes a vessel’s dimensions or extends its life has four defined criteria; any such proposed work needs to be forwarded to the Coast Guard. In response to a question, Phillips said a major conversion determination request goes straight to the headquarters of the Marine Safety Center. A request would typically come regarding work the company already knows it wants done, she said. She said any situation discovered during a drydock, rather than planned for, would come under the heading of repair or restoring original specifications. “Hopefully, there wouldn’t be a situation where you would put a vessel in drydock and only then discover then you need a major conversion.” Most of the time the Marine Safety Center responds within 30 days or fewer, she said.
Phillips noted that when the Coast Guard has finished its current review of the AWO’s best practices document, it will forward it (along with any added recommendations) to its field offices, and OCMI’s will “take into consideration” those principles and practices when conducting inspections. Parsonage thanked Phillips and said her answers “provided a lot of clarity.”
Rob Keister, a former Coast Guard inspector himself and now a vice president at Sabine Surveyors, a leading TPO, said his company had conducted 37 drydock inspections of vessels since the inauguration of Subchapter M. Since the Coast Guard has not yet approved any new set of best practices, “we’re pretty much stuck with NVIC 7-68,” he said, and its guidance on doubler plates, along with existing ABS hull standards. “Most of our customers have embraced inserts and radius corners” in repairs, he said.
Tava Foret noted that TVIB client companies have performed 814 annual surveys, but only six drydock internal structural exams to date. Its customers are using a 50/50 mix of internal and external (TPO) inspectors for their drydock surveys. The pending Coast Guard guidance “can’t come soon enough,” she stressed. She praised the Coast Guard’s Towing Vessel Center of Expertise for keeping up communication and noted that TVIB has submitted three questions to them for further clarification.
Stewart pointed out that the best practices document being developed by AWO is for everyone in the industry to use, not just AWO members. It’s designed to be a “toolbox,” and there has been no decision on whether it will become a part of AWO’s Responsible Carrier Program (RCP). Many member companies already include them as part of their TSMS.
In the question and answer period, Keister noted that along the Gulf Coast, at least, there are plenty of drydocks available for hull inspections, due to the oil slump. Further north, drydock availability may be an issue, and he suggested that companies schedule drydockings early. “Scheduling is key” he said. “Don’t wait for the end of your period!”