U.S. Coast Guard
Homeland Security
Applicability of International Regulations for Uninspected Towing Vessels (UTV)
Towing Vessel National Center of Expertise
U.S. Coast Guard
Homeland Security Objectives
Towing Vessel National Center of Expertise
• Identify key international reference materials for UTVs.
• Determine when a UTV engages in international/foreign voyages.
• Determine international requirement applicability based on build date/Gross Register Tons/Gross Tonnage, International Tonnage Convention.
• Determine international requirement applicability to an Uninspected Towing Vessels (UTV).
U.S. Coast Guard
Homeland Security References
Towing Vessel National Center of Expertise
• SOLAS (various)• MARPOL (Annex I - III and V – VI)• STCW• ILLC• ISPS• ILO• NVIC 11-93 (Applicability of Tonnage Systems)• Various CFRs. For example:
• 46 CFR Part 69 (Measurement of Vessels)• 33 CFR Part 169 Subpart C (LRIT)• 33 CFR Subchapter O (MARPOL Annex I, II, V)• 33 CFR Subchapter H (MTSA)
U.S. Coast Guard
Homeland Security Foreign/Domestic Voyage
(Per 46 CFR 69.9 and NVIC 11-93 Ch-3)
Towing Vessel National Center of Expertise
Foreign Voyage:• Foreign port to US port• Foreign port to Foreign port• US port to Foreign port• US territory/possession to/from other port w/in US jurisdiction
Great Lakes Voyage:• A voyage on the Great Lakes
Domestic Voyage:• Not a foreign voyage• Not a Great Lakes voyage
All “international voyages” are “foreign voyages” but…not all foreign voyages are international voyages.
U.S. Coast Guard
Homeland Security Tonnage Systems
Towing Vessel National Center of Expertise
GRT (Gross Register Tons)• US Regulatory measurement system (standard, dual,
simplified)• US tonnage system with a historical basis – prior to 1983
this was the only measurement system• AKA: GT, national tonnage, gross tons, regulatory tonnage
GT ITC (Gross Tonnage, International Tonnage Convention)• US tonnage measurement system to comply with
International Convention on Tonnage Measurement of Ships, 1969
• AKA: ITC, convention tonnage, gross tonnage
U.S. Coast Guard
Homeland Security Ton/Tonnage
Towing Vessel National Center of Expertise
• Ton/Tonnage = Volume of a vessel’s enclosed spaces
• Standard, duel and simplified measurement systems (GRT) based on tons of 100 cubic feet
• Convention measurement system (GT ITC) base on tons of 100 cubic feet modified by logarithmic function.
What is it??
U.S. Coast Guard
Homeland Security Gross Tons/Tonnage
Towing Vessel National Center of Expertise
• Gross tonnage (GT) = A vessel’s approximate volume
• Standard, dual measurement systems: GT = Volume of enclosed spaces – exempted spaces
• Simplified measurement systems: Length, depth, breadth modified by a coefficient:For example…GT = 0.67 LDB/100 (depends on hull shape)
• Convention measurement system: All enclosed spaces modified by a coefficient: GT = K1 V V = total volume of all enclosed spaces in cubic meters K1 = 0.2+0.2 log10 V
What is it??
U.S. Coast Guard
Homeland Security Net Tons/Tonnage
Towing Vessel National Center of Expertise
• Net tonnage (NT) = A vessel’s earning capacity
• Standard, duel measurement systems = NT = Gross tonnage – deducted spaces
• Simplified measurement systems = Gross tonnage modified by a coefficient:NT for self-propelled non-sailing vessel = (GT)(0.80)
• Convention measurement system = Volume of passenger and cargo spaces modified by a formula based on the vessel’s volume:NT = K2VC(4d/3D)2+K3(N1+(N2/10))
What is it??
U.S. Coast Guard
Homeland Security
Key Points
Towing Vessel National Center of Expertise
UTVs that engage in foreign voyages must be in compliance w/all applicable international requirements
Each vessel is evaluated on a case by case basis:• Build date• Applicable tonnage system• When international requirements became effective
U.S. Coast Guard
Homeland Security
Build Date
Towing Vessel National Center of Expertise
Build date is:• The date the keel was laid – no substantial alteration
or• The date the vessel was substantially altered:
• A change of more than 1% in GRT or GT ITC for vessels built before 18JUL82
• A change of more than 5% in GRT or GT ITC for all vessels built on or after 18JUL82
• Use the most recently altered date as the build date
Existing Vessels
18JUL1982
Interim Scheme Vessels
31DEC85 18JUL1994
All Vessels Vessel’s <1600 GT New Vessels
U.S. Coast Guard
Homeland Security
Applicable Tonnage System
Towing Vessel National Center of Expertise
• A vessel-specific determination
• Key document - NVIC 11-93 Ch-3
• Tonnage questions unanswered by the NVIC should be directed your TVNCOE rep
• Some questions may be more appropriately answered by CVC-1 and/or the Tonnage Division at the Marine Safety Center (MSC-4)
• Requests for formal vessel specific determinations go through MSC-4 which is similar to plan review process
U.S. Coast Guard
Homeland Security
General Tonnage System Applicability
Towing Vessel National Center of Expertise
• Vessels with a build date before July 18, 1994 can use their GRT for some international requirements, but must use GT ITC to comply with certain international requirements
• Vessels with a build date on or after July 18, 1994, must comply with ALL international requirements using their GT ITC
• Gross tonnage does not always mean gross tons, it could be telling you which tonnage measurement system is to be used. Be sure to check definitions!!
Existing Vessels
18JUL1982
Interim Scheme Vessels
31DEC85 18JUL1994
All Vessels Vessel’s <1600 GT New Vessels
GT ITCGRT/GT ITC
U.S. Coast Guard
Homeland Security
Example
Towing Vessel National Center of Expertise
Built in 1978GRT is 198 and GT ITC is 858NRT is 135 and NT ITC is 257Length overall 123 ftConvention length 118 ftVessel goes international (foreign)No substantial alterations
Do they have to comply with:• MARPOL Annex VI (IAPP)?• LRIT?• GMDSS?
YESYES
NO
U.S. Coast Guard
Homeland Security
Example
Towing Vessel National Center of Expertise
Built in 1978GRT is 198 and GT ITC is 832NRT is 135 and NT ITC is 257Length overall 123 ftConvention length 118 ftVessel goes international (foreign)New construction GT ITC was 858 (alteration date 01NOV1996)
Do they have to comply with:• MARPOL Annex VI (IAPP)?• LRIT?• GMDSS?
YESYES
YES
U.S. Coast Guard
Homeland Security
General Tonnage System Applicability for Vessels With Build Dates Before 18JUL94
Towing Vessel National Center of Expertise
Can use GRT for:• GMDSS• MARPOL (except Annex VI) • SOLAS (some exceptions)• Safe Manning Document
Must use GT ITC for:• LRIT• ISM• ISPS• MARPOL Annex VI• STCW
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
U.S. Coast Guard
Homeland Security
Issuing Certificates to UTVs Not Subject to Certain Requirements
Towing Vessel National Center of Expertise
• Reason…facilitate the operation of the US maritime industry
• Upon request, the CG can issue certificates even though a international convention does not apply to the vessel - i.e. ISSC and SMD
• Examiners should encourage owners and operators to take advantage of this opportunity to avoid delays while conducting business in a foreign port
U.S. Coast Guard
Homeland Security
Documents (Not on the exam form)
Towing Vessel National Center of Expertise
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
International Tonnage Certificate
• 46 CFR Part 69
• >=79 ft
• GT/NT IAW the 1969 Tonnage Convention (ITC)
• Permanent except in case of alterations or upon transfer of the ship to the flag of another State
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Stability Letter
• 46 CFR Part 42
• New Vessels >= 79 ft
• New vessel = built on/after:• 21JUL68 for Domestic/Intn’l• 28SEP37 for Special Service• 27AUG36 for Great Lakes
• Existing Vessels = Vessels that are not new vessels
• Existing vessels are not required to have stability letter – 46 CFR 42.15-1 only applies to a “new vessel”
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
International Oil Pollution Prevention Certificate• MARPOL Annex I
• 33 CFR 151.19
• >= 400 GT
• Issued by CG or Class on behalf of CG
• Valid for 5 years
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
OIL RECORD BOOK
• MARPOL Annex I• 33 CFR 151.25
• >= 400 GT
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Document of Compliance
• SOLAS Reg IX/4
• >= 500 GT ITC
• Issued to a company that complies with the requirements of the ISM Code
• Copy kept on board vessel
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Safety Management Certificate
• SOLAS Reg IX/4
• >= 500 GT ITC
• Issued to a vessel that operates in accordance with the companies approved safety management system
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
International Ship Security Certificate
• ISPS Code• 33 CFR 104.297
• >= 500 GT ITC
• Issued by CG to a vessel that operates in accordance with applicable parts of the ISPS code.
• Issued to vessel < 500 GT ITC upon request
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Continuous Synopsis Record
• SOLAS Reg XI-1/5
• >= 500 GT
• Provides an on-board record of the history of the ship
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Cargo Ship Safety Construction Certificate• SOLAS Reg I/12
• >= 500 GT
• Shows vessel complies with applicable part of SOLAS chapters II-1 and II-2
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Cargo Ship Safety Equipment Certificate
• SOLAS Reg I/12
• >= 500 GT
• Shows vessel complies with applicable part of SOLAS chapters II-1, II-2, III and V
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Cargo Ship Safety Radio Certificate
• SOLAS Reg I/12
• >= 300 GT
• Shows vessel complies with applicable part of SOLAS chapter IV
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Cargo Ship Safety Certificate
• SOLAS Reg I/12
• >= 500 GT
• Shows vessel complies with applicable part of SOLAS chapters II-1, II-2, III IV and V
• Can be used an alternative for the CSSCC, CSSEC, or CSSRC
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Other Certificates/Documents
• SOLAS:• Fire Control Plan (500 GT):
• < 01JUL02 74/78 Reg II-2/20.2• >= 01JUL02 04 Cons Reg II-2/15.2.4.2
• MARPOL (400 GT):• Garbage Management PL Reg V/9• Garbage Record Book Reg V/9• International Air Pollution Prevention Certificate
Reg VI/6
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Long Range Identification and Tracking
SOLAS Ch-V Reg. 19-1 2.1 33 CFR 169.205
• >= 300 GT ITC
• Shows vessel complies with LRIT requirements
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Compass Deviation Card
• SOLAS Ch-V Reg. 19.2.1.3 • 33 CFR 164.72(a)(4)-
requires magnetic compass only
• All ships irrespective of size required to have a properly adjusted magnetic compass
and a means of correcting to true at all times
U.S. Coast Guard
Homeland Security
Towing Vessel National Center of Expertise
Life Raft Inspection Certificate• IMO resolution A761(18)
• Indicates the life raft(s) have been surveyed, controlled and tested in compliance with USCG/SOLAS requirements
U.S. Coast Guard
Homeland Security
Questions
Towing Vessel National Center of Expertise