Engine and galley exhaust ducts, installed on new and existing vessels, must be appropriately insulated.  Insulation installations must be to the satisfaction of the OCMI or TPO as appropriate.  Compliance with ABYC P-1 or NFPA 302 is objective evidence of compliance with this requirement.

Items to check:

• Internal combustion engine exhaust ducts, galley exhaust ducts, and similar ignition sources properly insulated if less than 18 inches (450mm) away from combustible material.   

Regulatory Cites:

46 CFR 136.112
46 CFR 144.415

Additional Guidance:

ABYC Standard P-1
NFPA Standard 302

A definition for “rest” can be found in 46 CFR 15.1101(a)(4).
 

Items to check:

• Accommodation and work spaces suitable for the size, facilities service, route and modes of vessel operation.
• Accommodation space overhead not located below the deepest load waterline.
• Overnight accommodations if the same crew operates the vessel more than 12 hours in a 24 hour period.
• Provide suitable environment for sleep and off-duty rest. 

Regulatory Cites:

46 CFR 15.1101 General
46 CFR 144.700 General requirements
46 CFR 144.710 Overnight accommodations
46 CFR 144.720 Crew rest consideration

Additional Guidance:

Marine Safety Manual Volume II

There is no requirement in Subchapter M for new construction oversight by the Coast Guard or a TPO; however, TPOs who will be providing such oversight should develop their own oversight process and incorporate the same into their Quality Management System.

New towing vessels are required to verify compliance with Subchapter M design standards prior to issuance of the initial COI.  Deviations from the verified design standards will need to be corrected before the vessel enters service.  Existing towing vessels must have their proposed modifications verified for compliance with design standards prior to the modifications.

Verification of compliance with design standards conducted by a licensed professional engineer (PE) or a classification society are not conducted under the guidance of NVIC 10-82 or NVIC 10-92, so these verifications are not required to be submitted to the Coast Guard for final approval or authorization.

If the owner or managing operator would like the Coast Guard to conduct the design verification, they must first submit Form CG-3752, “Application for Inspection of U.S. Vessel,” to the cognizant OCMI where the construction will take place. The local OCMI will then provide guidance as to which plans are required for submission and identify which, if any, will be forwarded to the MSC for review.

Items to check:

• Required design verification complete IAW 46 CFR Part 144
• No deviations from verified design standards

Regulatory Cites:

46 CFR 144.135 Verification of compliance with design standards
46 CFR 144.140 Qualifications
46 CFR 144.145 Procedures for verification of compliance with design standards

Additional Guidance:

NVIC 10-82, CH-2 Acceptance of Plan Review and Inspection Tasks Performed by the American Bureau of Shipping for New Construction or Major Modifications of U.S. Flag Vessels
NVIC 10-92 CH-2 Coast Guard Recognition of Registered Professional Engineer Certification of Compliance with Coast Guard Requirements
Marine Safety Center Technical Note 01-17 Ch-1, Guidance on Design Verification for Subchapter M Towing Vessels
Marine Safety Center Design Verification Guideline Number H1-18, Review of General Arrangements for Towing Vessels

Items to check:

• All exposed hazards such as gears and rotating machinery are protected by cover, guard or rail.
• Access to equipment such as towing gear, steering gear, winches, drums and other equipment needed in the operation of the vessel not restricted by guards.   

Regulatory Cites:

46 CFR 144.820 Guards in dangerous places

Certain towing vessels subject to Subchapter M, handrails will also need to meet minimum height requirements – i.e. Loadline vessels).

Items to check:

• Rails or equivalent protection installed near periphery of all decks accessible to crew.
• Hand grabs are available in locations where deck rails are impractical.   

Regulatory Cites:

46 CFR 144.800 Handrails and bulwarks

New Towing vessels must meet the requirements of 46 CFR part 173, Subpart B.

Regulatory Cites:

46 CFR 144.310 Lifting requirements for a new vessel.
46 CFR Part 173, Subpart B Lifting

Items to check:

• Bulkheads separate machinery and fuel tank spaces from accommodation spaces.  

Regulatory Cites:

46 CFR 144.410 Separation of machinery and fuel tank spaces from accommodation spaces

Items to check:

• Hull of documented vessel marked as required by 46 CFR Part 67.
• Hull of undocumented vessel marked with its name and hailing port.
• Vessel complying with 144.300(a) or 144.305 must have draft marks that meet requirements of 46 CFR 97.40-10
• Loadline vessel has loadline marks and deck line permanently scribed or embossed as required by 46 CFR Part 69 Subchapter E.
• Watertight doors and hatches marked in accordance with 144.160 (e)
• Emergency and escape hatches marked in accordance with 144.160 (f) 

Regulatory Cites:

46 CFR 67 Documentation of Vessels
46 CFR 69 Measurement of Vessels
46 CFR 97.40-10 Draft marks and draft indicating systems
46 CFR 144.160 Marking
46 CFR 144.300 Stability standards for an existing vessel
46 CFR 144.305 Stability standards for a new vessel

Items to check:

• Each mattress complies with either:
  • U.S. Department of Commerce Standard for Mattress Flammability (FF 4-72.16) 16 CFR  part 1632 Subpart A and not contain polyurethane foam.
  • IMO Resolution A.688 (17) Fire test procedures for ignitability of bedding components.     

Regulatory Cites:

46 CFR 144.430

Additional Guidance:

16 CFR Part 1632, Subpart A
IMO Resolution A.688 (17)

NVIC 9-97 Ch-1 provides guidance regarding means of escape on commercial vessels.

46 CFR 144.515(b) is one of the parameters (no sources of fire) that must be met in order to utilize one means of escape from a space.  For the purposes of this subparagraph, a portable heater with an open flame, resistance coil, or fuel source is considered a source of fire. An installed baseboard or wall-mounted radiator/vent in a space should not be considered a source of fire.

Items to check:

• Each crew living and working space has adequate number of means of escape.
• Located at opposite end or sides of space - may include passageways, stairways, ladders, deck scuttles, doors, and windows.
• If window is used as a means of escape meets requirements of 144.510.
• If utilizing one means of escape from a space meets requirements of 144.515

Regulatory Cites:

46 CFR 144.500 Means of escape
46 CFR 144.505 Location of escapes
46 CFR 144.510 Window as a means of escape
46 CFR 144.515 One means of escape required

Additional Guidance:

NVIC 9-97 Ch-1 Guide to Structural Fire Protection

Items to check:

• Windows at operating station provide clear field of vision for safe operation in any weather condition.
• Windows forward of the operating station in the pilot house have means to ensure safe navigation regardless of weather conditions:
  • Windshield wipers
  • Clear-view Screens
  • Defoggers   

Regulatory Cites:

46 CFR 144.905 Operating station visibility

Items to check:

• Exhaust pipes from internal combustion engines within reach of personnel are insulated and/or guarded.
• New vessels each pipe that contain vapor, gas, or liquid that exceeds 150°F or 65.5°C within reach of personnel must be insulated and/or guarded.   

Regulatory Cites:

46 CFR 144.830 Protection against hot piping

Further discussion about stability standards can be found in the Part 144 FAQs.  

Items to check:

• Any stability documents issued to the vessel are readily available.
• If a new towing vessel, meets the applicable stability standards of 46 CFR Part 170 and 173. 

Regulatory Cites:

46 CFR 144.300 Stability standards for an existing vessel
46 CFR 144.305 Stability standards for a new vessel

Additional guidance:

Marine Safety Center DVG Number H1-04, Review Stability for Towing Vessels (M)
NVIC 14-81, Stability Tests; Waiving of for “Sister Vessels”
NVIC 10-83, Stability Approval and the Issuance of Stability Letters
NVIC 12-83, Intact Stability of Towing Vessel and Fishing Vessels; Research Results
NVIC 17-91, Guidelines for Conducting Stability Tests
Marine Safety Manual Volume II
FAQs Part 144 – see 144-001, -003, -014, -024

Certain towing vessels subject to Subchapter M, handrails will also need to meet minimum height requirements – i.e. Loadline vessels).

Items to check:

• Storm rails or hand grabs installed in all passageways and deckhouse sides.   

Regulatory Cites:

46 CFR 144.810 Storm rails

The OCMI may consider a vessel as “overbuilt” when compared to acceptable construction standard(s), such as ABS Rules for Steel Vessels Under 90 Meters (295 Feet) in Length.  Requests for increased wastage allowance based on the vessel being overbuilt may be submitted in writing to the local OCMI.  Requests should offer suitable verification, including objective evidence showing the vessel’s scantlings, (frames, girders, plating, etc.).  NVIC 7-68 and the Part 144 FAQs may be referenced for further clarification.

Items to check:  

• Meets structural standards for the intended service and route(s) per ABS Rules for Building and Classing Steel Vessels Under 90 Meters (295 Feet) in Length.
• Meets structural standards for the intended service and route(s) per ABS Rules for Building and Classing Steel Vessels for Service on Rivers and Intracoastal Waterways.
• Vessel has been in satisfactory service and has proven structurally adequate.    

Regulatory Cites:

46 CFR 144.120 A classed vessel
46 CFR 144.125 A vessel with a load line
46 CFR 144.130 A vessel built to the International Convention for the Safety of Life at Sea, 1974, as amended, requirements
46 CFR 144.200 Structural standards for an existing vessel
46 CFR 144.205 Structural standards for a new vessel
46 CFR 144.215 Special consideration

Additional Guidance:

NVIC 7-68 Notes on Inspection and Repair of Steel Hulls
FAQs Part 144 – see 144-013, -023, -048

An additional hazard in the event of fire is the spread of smoke through ventilation systems. Operation of ventilation dampers and smoke flaps should be verified. The marine inspector should also ensure that the master controls de-energization of ventilation fans operates as intended and that means are available for closing main inlets and outlets of ventilation systems.  The requirements of 144.605 are independent of the requirements for fixed fire extinguishing systems in part 142 and are applicable to all vessels, regardless of fire suppression systems onboard.

Items to check:

• Means available to stop each fan in a ventilation system serving a machinery space.
• Means of closing each doorway, ventilator, annular space around funnels or other openings in case of fire.
• If  vessel is greater than 65 ft in length and has overnight accommodations:
  • Vessel has mechanical ventilation or sufficient natural ventilation available.     

Regulatory Cites:

46 CFR 144.605 Means to stop fans and close openings
46 CFR 144.610 Ventilation in a vessel more than 65 feet in length

Items to check:

• All waste receptacles constructed of non-combustible materials with no openings on sides or bottom.  

Regulatory Cites:

46 CFR 144.425 Waste receptacles

Items to check:

• Scuppers and freeing ports on installed bulwarks not blocked.
• Closer devices for deckhouse or hull penetrations that open to exterior of vessel operate properly.   

Regulatory Cites:

46 CFR 144.320 Watertight or weathertight integrity

Additional guidance:

NVIC 2-62 Watertight Bulkheads in All Inspected Vessels Maintenance of Watertight Integrity

Items to check:

• Windows, portlights, and its means of attachment to the hull suitable for maximum load expected from wind waves.
• Coverings or protection over a window or portlight used as an escape readily removed or opened from within the space.
• Windows made of materials that will not fracture into dangerous fragments if fractured.

Regulatory Cite:

46 CFR 144.920 Window or portlight strength in a new vessel.