NVIC 02-81: Inspection guidance for integrated tug-barge combinations

Commandant US Coast Guard Stop 7501 United States Coast Guard 2703 Martin Luther King Jr Ave SE Washington, DC 20593-7501 Staff Symbol: CG-CVC Phone: 202-372-1210 Email: CGCVC@uscg.mil COMDTCHANGE NOTE 16700 NVIC 02-81 Ch-2 18 JUL 2023 COMMANDANT CHANGE NOTICE 16700 Subj: CH-2 TO COAST GUARD INSPECTION GUIDANCE REGARDING INTEGRATED AND ARTICULATED TUG BARGE COMBINATIONS

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — PURPOSE. This Commandant Change Notice publishes a change to Coast Guard Inspection

Guidance Regarding Integrated Tug Barge Combinations, Navigation and Vessel Inspection Circular NVIC 02-81 Change 1 dated February 25, 1981.

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — ACTION. Officers in Charge, Marine Inspection (OCMI) should bring this notice to the

attention of marine inspectors and the maritime industry within their zones responsibility. Internet release authorized.

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — DIRECTIVES AFFECTED. With the addition of this Commandant Change Notice, Coast

Guard Inspection Guidance Regarding Integrated Tug Barge Combinations NVIC 02-81 (Change 1) is updated. CG-CVC Policy Letter 16-04 Conditional Occupancy of Unmanned Barges Forming Part of an Articulated Tug Barge (ATB) Combination has been incorporated into this update and is cancelled.

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — DISCLAIMER. The guidance is not a substitute for applicable legal requirements, nor is it

itself a regulation. It is not intended to impose, nor does it impose legally binding requirements on any party. It represents the Coast Guard’s current thinking on this topic and and is issued for guidance purposes to outline methods of best practice for compliance with applicable law. You may use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations.

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — MAJOR CHANGES. This Commandant Change Notice revises NVIC 02-81 Change 1 as

follows: a. The subject of the policy was broadened to provide the marine industry and Coast Guard personnel with uniform guidance regarding the application of certain statutes and Coast Guard regulations to push-mode Integrated Tug Barge combinations (hereafter referred to as “ITBs”) and replaces the use of the term “dual-mode ITBs” with Articulated Tug Barge combinations (hereafter referred to as “ATBs”). Subj: CH-2 TO COAST GUARD INSPECTION GUIDANCE REGARDING 16700 INTEGRATED AND ARTICULATED TUG BARGE COMBINATIONS 18 JUL 2023 b. Updated Enclosure (1) to include the requirement for inspected towing vessels. With the implementation of 46 CFR Subchapter M – Towing Vessels, as of July 19, 2022, all towing vessels to which 46 CFR Subchapter M apply, were required to obtain a Certificate of Inspection (COI). As such, all ITB and ATB tug and barge units will each be issued a COI, be inspected to the standards of the required vessel subchapter (i.e., subchapters M, I, D, etc.) individually, and obtain documents (i.e., COD, load line, IOPP, etc.) as described in enclosure 1. c. Added a new enclosure (2) which incorporated CG-CVC Policy Letter 16-04 Conditional Occupancy of Unmanned Barges Forming Part of an Articulated Tug Barge (ATB) Combination into the NVIC, regarding guidance for authorizing conditional occupancy equivalency endorsments on unmanned ATB barges.

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — ENVIRONMENTAL ASPECTS AND IMPACT CONSIDERATIONS.

a. This NVIC and the general policies it contains have been thoroughly reviewed by the originating office, and are categorically excluded from further environmental analysis under Coast Guard Categorical Exclusion (CE) #33, in accordance with Section 2.B.2 and Figure 2-1 of the National Environmental Policy Act Implementing Procedures and Policy for Considering Environmental Impacts, COMDTINST M16475.1D. This NVIC is a guidance document intended to enhance implementation and compliance with applicable Coast Guard regulations; it does not amend or change any provision, authorization or requirement found in statute or regulation. Use of CE #33 is appropriate.1 b. This NVIC will not result in any of the following: significant cumulative impacts on the human environment, substantial controversy or substantial change to existing environmental conditions, or inconsistencies with any Federal, State, or local laws or administrative determinations relating to the environment.

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — DISTRIBUTION. No paper distribution will be made of this Commandant Change Notice.

An electronic version will be located on the Coast Guard NVIC website: https://www.dco.uscg.mil/Our-Organization/NVIC/

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — RECORDS MANAGEMENT CONSIDERATIONS. This Commandnat Change Notice has

been thoroughly reviewed during the directives clearance process and it has been determined there are no further records scheduling requirements in accordance with the Federal Records Act, (44 U.S.C. § 3101 et seq.), NARA requirements, and the Information and Life Cycle Management Manual, COMDTINST M5212.12 (series). This NVIC does not create a significant or substantial change to existing records management requirements.

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — FORMS/REPORTS. None.

1 CE #33 provides: “Preparation of guidance documents that implement, without substantive change, the applicable Commandant Instruction or other Federal agency regulations, procedures, manuals, and other guidance documents.” Subj: CH-2 TO COAST GUARD INSPECTION GUIDANCE REGARDING 16700 INTEGRATED AND ARTICULATED TUG BARGE COMBINATIONS 18 JUL 2023

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — REQUEST FOR CHANGES. All requests for changes or questions regarding this NVIC and

this Commandant Change Notice should be directed to Commandant (CG-CVC) staff at CGCVC@uscg.mil. W. R. Arguin Rear Admiral, U. S. Coast Guard Assistant Commandant for Prevention Policy Commandant US Coast Guard Stop 7501 United States Coast Guard 2703 Martin Luther King Jr Ave SE Washington, DC 20593-7501 Staff Symbol: CG-CVC Phone: 202-372-1210 Email: CGCVC@uscg.mil COMDTPUB P16700 NVIC 02-81 Ch.2 18 Jul 2023 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 02-81, CHANGE 2 Subj: COAST GUARD INSPECTION GUIDANCE REGARDING INTEGRATED AND ARTICULATED TUG BARGE COMBINATIONS Ref: (a) 46 United States Code (U.S.C.) § 3301, Vessels Subject to Inspection

(b) Title 46 Code of Federal Regulations (CFR), Chapter I, Coast Guard, Department of Homeland Security

(c) 46 CFR Chapter I, Subchapter M, Towing Vessels

(d) Marine Safety Manual, Vol III, Marine Industry Personnel, COMDINST 16000.8B

(e) 46 CFR Chapter I, Subchapter B, Merchant Marine Officers and Seamen 1. PURPOSE. The purpose of this Circular is to provide the marine industry and Coast Guard personnel with uniform guidance regarding the application of certain statutes and regulations to Integrated Tug-Barge combinations (ITBs) both in the push-mode and dual-mode configurations. Dual-mode ITBs are now commonly known as Articulated Tug-Barges

(ATBs).1 Additionally, this Circular provides criteria for how non self-propelled vessels as part of an ATB unit may be conditionally occupied. 2.

DISCLAIMER.

This guidance is not a substitute for applicable legal requirements, nor is it itself a regulation.

It is not intended to, nor does it impose legally binding requirements on any party.

It represents the Coast Guard’s current thinking on this topic and is issued for guidance purposes to outline methods of best practice for compliance with the applicable law.

You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. 3.

ACTION. a.

This guidance is effective on the publication date.

This Circular is not applicable to tug barge combinations with routes restricted to lakes, bays and sounds, or rivers, as defined in Title 46 CFR subpart 90.10. b.

Officers in Charge, Marine Inspection (OCMIs) shall be familiar with the guidance contained in this Circular and should share and discuss this information with local 1Although “dual-mode ITB” and “ATB” are functionally the same vessel combination for inspection purposes, the “dual-mode ITB” designation is still used by Coast Guard for other purposes, [and so is used herein for consistency].

Subj: COAST GUARD INSPECTION GUIDANCE REGARDING 5400 INTEGRATED AND ARTICULATED TUG BARGE COMBINATIONS 18 Jul 2023 maritime industry stakeholders.

OCMIs should ensure that all marine inspectors have a thorough understanding of the compliance and enforcement procedures discussed in this Circular. c.

When inspecting ITB/ATB tugs and barges, OCMIs should refer to enclosures (1) and (2) for particular considerations concerning inspection, applicability of tonnage-based requirements, manning, conditional occupancy of barges assigned unmanned load lines, firefighting and life saving, etc. d.

OCMIs should ensure that the Certificate of Inspection (COI) endorsements and the Marine Information for Safety and Law Enforcment (MISLE) system entries are accurate, based on the guidance within enclosures (1) and (2). e.

Vessel owners or managing operators should ensure compliance with this Circular, its enclosures, and references (a) through (e), as applicable, for vessel inspection requirements based on the vessel’s size, operating area, and mode of operation. 4.

DIRECTIVES AFFECTED.

As of the publication of this NVIC Change 2, CG-CVC Policy Letter 16-04 is cancelled. 5.

BACKGROUND. a.

When this NVIC was originally published in 1981, interconnected combinations of tugs and barges, generally known as “integrated tug barges” (ITBs), were an evolving concept based on mechanical systems that locked the tug into a specially-designed stern notch on the barge (rather than relying on conventional lashing or towing methods using lines, wire ropes, etc.).

ITB tugs and barges were designed to operate jointly as a combined unit, which raised novel issues with respect to design, construction, operation, manning, inspection, and certification.

This NVIC was written to provide guidance on those novel issues to Coast Guard plan reviewers and inspectors, and to ITB designers, builders, and operators. b.

At that time, the Coast Guard categorized the combinations as “push-mode” or “dual-mode” ITBs.

Over the next forty years, the ITB concept matured.

The “push-mode” ITB did not prove to be commercially successful; only a few were ever built and there have been no new ones constructed since the 1980s.

On the other hand, the “dual-mode” ITB was very successful and has evolved into the “articulated tug-barge” (ATB) of today.

Experience has been gained by both Coast Guard and industry, a variety of interconnection systems have been developed, and several class societies now have rules specifically pertaining to the design and construction of ATB tugs, barges, and interconnection systems.

Furthermore, provisions have been established where unmanned ATB barges may be conditionally occupied by personnel performing non-navigational tasks while transiting offshore.

Consequently, the guidance in this NVIC is updated to reflect current state of push mode ITBs and ATB design and operations. 6.

DISCUSSION. a.

ATB/ITB tugs and barges can be distinguished from ordinary tugs and barges by virtue of each being outfitted with a special interconnection system that allows them to be mechanically locked together.

A barge without such an interconnection system, even with Subj: COAST GUARD INSPECTION GUIDANCE REGARDING 5400 INTEGRATED AND ARTICULATED TUG BARGE COMBINATIONS 18 Jul 2023 a notched stern where any tug can lash itself into place, is not an ITB or ATB barge, and is not covered by this NVIC. b.

Many provisions in the original NVIC have since been incorporated into other Coast Guard regulations and policies.

For example: Towing vessels were not inspected until 2017 but are now subject to inspection per reference (c); also, other original provisions

(such as manning and sea time credit) are now covered by references (d) and (e). Consequently, enclosure (1) has been updated to address only those aspects of ATB/ITB tug and barge inspections that are not covered elsewhere. c. Conditional occupancy of unmanned ATB/ITB barges.2 ATB/ITB barges are typically assigned unmanned load lines. However, operators often request to perform certain activities onboard the barges during coastwise transits, such as routine maintenance of barge equipment and cargo systems, or discharge preparations ahead of arrival to a port. Enclosure (2) discusses special safety provisions whereby personnel may be conditionally permitted to work aboard an ATB barge operating under an unmanned load line. If the criteria within enclosure (2) section 6 are met, OCMIs may grant a request to conditionally occupy an ATB barge.3 7. ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS. The development of this NVIC and the general policies contained within it have been thoroughly reviewed by the originating office in conjunction with the Office of a. Environmental Management, Commandant (CG-47). This NVIC is categorically excluded under current Department of Homeland Security (DHS) categorical exclusion

(CATEX) A3 from further environmental analysis in accordance with "Implementation of the National Environmental Policy Act (NEPA)", DHS Instruction Manual 023-01-001- 01 (series). This NVIC will not have any of the following: significant cumulative impacts on the human environment; substantial controversy or substantial change to existing b. environmental conditions; or inconsistencies with any Federal, State, or local laws or administrative determinations relating to the environment. All future specific actions resulting from the general policy in this NVIC must be individually evaluated for compliance with the National Environmental Policy Act (NEPA), Department of Homeland Security (DHS) and Coast Guard NEPA policy, and compliance with all other applicable environmental mandates. NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-22 5. 8. DISTRIBUTION. No paper distribution will be made of this NVIC. An electronic version will be located at https://www.dco.uscg.mil/Our-Organization/NVIC/. 2The term “conditional occupancy” is applied to these special situations in order to avoid possible confusion with “manning” and “permissive manning,” which is used by Coast Guard for other situations. For conditional occupancy purposes, “unmanned” herein refers to ATB/ITB barges assigned unmanned load lines. If the OCMI determines that the barge must be manned for other purposes, then it must be assigned a manned load line. 3 Per 46 CFR § 24.15–1(b) (subchapter C), 46 CFR § 30.15–1(b) (subchapter D), 46 CFR § 42.03–20(b)

(subchapter E), and 46 CFR § 90.15–1(b) (subchapter I). Requests for equivalents outside of enclosure 2 criteria must be submitted to Commandant (CG-ENG) for approval. Subj: COAST GUARD INSPECTION GUIDANCE REGARDING 5400 INTEGRATED AND ARTICULATED TUG BARGE COMBINATIONS 18 Jul 2023 9. RECORDS MANAGEMENT CONSIDERATIONS. This NVIC has been thoroughly reviewed during the directives clearance process, and it has been determined there are no further records scheduling requirements, in accordance with Federal Records Act, 44 U.S.C . § 3101 et seq., NARA requirements, and Information and Life Cycle Management Manual, COMDTINST M5212.12 (series). This policy does not create significant or substantial change to existing records management requirements. 10. FORMS/REPORTS. None.

Coast Guard Inspection Guidance Regarding Integrated Tug Barge Combinations — REQUEST FOR CHANGES. All requests for changes and questions regarding

implementation of this NVIC and/or requests for changes should be directed to CG-CVC staff a CGCVC@uscg.mil. W. R. Arguin Rear Admiral, U.S. Coast Guard Assistant Commandant for Prevention Policy Encl: (1) Guidelines for Integrated Tug and Barge Combinations (2) Guidelines for Conditional Occupancy of Unmanned Barges Forming Part an Articulated Tug Barge (ATB) Combination