Page 14: of Marine News Magazine (September 2011)

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14MNSeptember 2011OPINIONOn August 11, the U.S. Coast Guard issued a long anticipated notice of proposed rulemaking that would establish a historic new inspection program for towing vessels, including a requirement for a safety management system as recommended by the National Transportation Safety Board. The American Waterways Operators hails this historic action as it will increase safety, security and environmental stewardship throughout the tugboat, tow- boat and barge industry. BACKGROUND In 2003, AWO took the unprecedented step of request- ing that the Commandant of the Coast Guard ask Congress for the authority to establish a new inspection regime unique to towing vessels. This authority was granted in the Coast Guard and Maritime Transportation Act of 2004. Since 2004, AWO has worked closely with the Coast Guard through the Towing Safety Advisory Committee to craft a 21st century approach to towing vessel inspection, one that focuses on the biggest cause of towing vessel casualties: human error. AWO S AFETY LEADERSHIPAWO members have a long history of safety leadership in the industry, demonstrated through the AWO Responsible Carrier Program, a safety and environmental protection program with which all AWO members must be in audited compliance as a condition of membership. Since the adoption of the AWO RCP, the industry has made great strides in enhancing safety, achieving a signif- icant reduction in crew fatalities, oil spills, and vessel casu- alties. However, AWO believed that industry safety would benefit even further from the establishment of a Coast Guard inspection program, including a requirement that all towing vessels implement a safety management system. In September 2000, as part of the m/v Anne Holly acci- dent investigation, the NTSB recommended that the Coast Guard require domestic towing companies to devel- op and implement a safety management system.GOVERNMENT -INDUSTRY COOPERATIVE APPROACH While this new inspection program is a historic change, it is also an outgrowth of years of cooperative work by AWO and the Coast Guard to improve maritime safety and environmental protection, including the innovative Towing Vessel Bridging Program, under which more than 3000 towing vessels have already undergone voluntary Coast Guard examinations to verify their compliance with safety and environmental stewardship requirements. Through the Coast Guard-AWO Safety Partnership, established in 1995, government and industry have worked together to tackle the most pressing safety prob- lems in the towing industry. FEATURESOFTHE PROPOSED TOWING VESSELINSPECTION PROGRAM The proposed regulations were developed with extensive input from the congressionally established TSAC. AWO and TSAC had recommended that the Coast Guard estab- lish a new subchapter of the Code of Federal Regulations containing, to the maximum extent possible, all of therequirements for inspected towing vessels. TSAC?s goal was to minimize cross-referencing and facilitate compli- ance by providing a one-stop answer to the question, ?What requirements does my towing vessel have to meet?? The NPRM largely does that, establishing a new 46 CFR Historic Towing Vessel Inspection NPRM Welcomed by Towing Industry In 2003, AWO took the unprecedented step of requesting that the Commandant of the Coast Guardask Congress for the authority to establish a new inspection regime unique to towing vessels. By Tom Allegretti, President & CEO, The American Waterways Operators MN#9 (1-17):MN 2011 Layouts 9/6/2011 3:36 PM Page 14

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