TOWING SAFETY ADVISORY COMMITTEE

TOWING SAFETY ADVISORY COMMITTEE September 10, 2008 MEMORANDUM TO: Towing Safety Advisory Committee FROM: Thomas McWhorter, Chairman, Economic Anal...
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TOWING SAFETY ADVISORY COMMITTEE September 10, 2008 MEMORANDUM TO:

Towing Safety Advisory Committee

FROM:

Thomas McWhorter, Chairman, Economic Analysis Working Group

RE:

TSAC Economic Analysis Working Group Report

At the April 2008 TSAC meeting, the Economic Analysis Working Group (EAWG) was formed in order to assist the Coast Guard in collecting economic figures and statistics needed to support the agency’s economic impact assessment of the forthcoming towing vessel inspection system. The working group includes members of the TSAC Towing Vessel Inspection Working Group and other interested individuals who volunteered to participate. The EAWG met in Houston on June 30 and conducted subsequent work by conference call and email. At the June 30 meeting, Mr. Reed Garfield of the Coast Guard provided to the EAWG an Introduction Guideline focusing on four categories. Each category contained a series of questions that the Coast Guard wanted answered by the EAWG prior to the September 17-18 meeting of the full TSAC in Linthicum, MD. At the June meeting, the EAWG addressed some of the questions, and assigned individuals to answer the remaining questions from the Introduction Guideline by the time of the TSAC meeting. A timeline for the EAWG was created that would allow for the collection of all data and the development and distribution of a draft report to TSAC at least one week prior to the September meeting. This memorandum constitutes the working group’s report. The draft report consists of the following sections: • • • • • •

Introduction (Pages 1-2) Processes and Procedures for Towing Companies (Pages 2-5) Processes and Procedures for Towing Vessels (Pages 5-8) Machinery and Equipment (Pages 8-13) Third-party Organizations (Pages 13-15) Appendix A (Page 16) Introduction

The Coast Guard must estimate the benefits and cost of the proposed regulations to establish an inspection regime for towing vessels. In order to do this, the Coast Guard must get a sense of current industry practices (i.e., develop a baseline) and determine what changes to current practices will be needed to comply with the forthcoming proposed regulations. The Coast Guard established the following guiding principles for the EAWG’s work:

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1. The Coast Guard does not seek and cannot use proprietary information. Due to Paperwork Reduction Act requirements, the agency cannot survey the industry. The Coast Guard is looking for a range of estimates based upon EAWG members’ experience and knowledge of the industry. 2. The Coast Guard recognizes that it is seeking information that is difficult to gather even for industry experts. The agency expects EAWG members to use their experience, impressions, judgment, considered assumptions, and tacit knowledge to answer the questions posed. In addition, the Coast Guard asks that the EAWG be clear about the limitations of the input provided. 3. The information provided by the EAWG is an essential input to the Coast Guard’s analysis of the economic impact of the proposed rule, but the final analysis must be prepared by the Coast Guard. The Coast Guard identified four categories of issues on which EAWG input was needed: processes and procedures for towing companies, processes and procedures for towing vessels, machinery and equipment, and third-party organizations. Processes and Procedures for Towing Companies These processes and procedures include requirements that companies operating towing vessels will be required to meet in order for their vessels to obtain a Certificate of Inspection. 1. What percentage of towing vessel companies has a safety management system (SMS)? The Coast Guard can answer this question by determining how many companies have vessels that are compliant with the International Safety Management (ISM) Code, adding that number to the number of American Waterways Operators (AWO) carrier members (approximately 210), and calculating a percentage based on the agency’s estimate of the total number of towing companies in the United States. (Coastal/ocean towing companies that operate vessels subject to SOLAS must comply with the ISM Code, and all AWO carrier members must comply with the AWO Responsible Carrier Program (RCP) as a condition of association membership. In addition, roughly 12% of members of the Dredging Contractors of America have adopted the Dredging Safety Management Program (DSMP), an SMS developed by DCA for dredging companies.) Inland or harbor towing companies that do not move oil and do not belong to AWO probably do not have an SMS. 2. Of those that have a SMS, what will be the changes and how much will it cost to have a compliant SMS? It is important to distinguish between the costs of developing and maintaining an SMS per se – e.g., staff or consultant costs to develop required policies and procedures, document control systems, internal and third-party auditing costs, etc. – and costs associated with Coast Guard requirements that must be reflected in the SMS (e.g., equipment costs, costs to drydock a vessel at specified intervals, etc.) The latter costs

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will be incurred not as a function of the requirement to have an SMS, but simply because they are required by the Coast Guard. For example, the requirements and costs below were identified by one working group member as new costs that will be incurred in order to bring the company’s safety management system into compliance with the proposed Subchapter M requirements. However, many of the items listed below are already present on most towboats, and will not represent new requirements for many companies. It is also important to note that the listed pieces of equipment are not a function of an SMS per se. Instead, they will be required in order to satisfy substantive requirements of Subchapter M. The data below is based on costs for 800 – 2000 horsepower towing vessels operating in and near the Corpus Christi to Port Arthur, TX. SMS-required equipment Engine room fixed pipe systems for MDE oil Power loss emergency light installation Fixed fire extinguisher system for galley stoves Engine room remote monitoring (cameras) Fire retardant paneling Multi-point alarm systems (10-30 points) Mechanical seals to facilitate dry bilges Electronic charting/AIS interface (wheelhouse) Electric start/stop E/R equip (wheelhouse control)

$4,000 $2,000 (avg. 8 lights @ $250 ea) $1,200 - $2,500 $1,500 - $3,000 $3,500 - $20,000 $10,000 - $22,000 $40,000 $1,200 - $9,700 $4,500

CEMS specific: Noise reduction (additional insulation) Blackout shades & green lighting RCP third party auditing/monitoring costs

$1,000 - $30,000 $1,000 $1,800 - $5,000

3. For those companies without an SMS, what is the range of costs to acquire a compliant SMS? The average cost for an individual company could be as high as $3,550 per vessel for the first year, or $100,000 to $150,000 for a large company. This number includes internal staff, consultants, document control equipment and auditing costs associated with startup. When evaluating this figure, it is important to contrast it with the costs associated with alternative forms of inspection. For example, there are likely to be cost savings associated with being able to contract with a larger number of third party auditors to perform required audits, versus the need to wait long periods of time for a limited number of Coast Guard inspectors. 4. Are the costs different for large companies than small companies? If so, why? Yes, because the costs for an SMS increase with the number of vessels covered. Large companies have to conduct more individual vessel audits. Additionally, large companies may have sub-offices or remote locations that must be audited as part of the required management system audit, adding additional travel time and auditing days for the 3rd

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party auditor. Big companies also have a larger burden to conduct internal audits on each vessel and shoreside location, which will require additional manpower. To conduct internal audits on a large fleet, this may mean hiring a full time staff, including salary, training and travel costs. While large companies will spend more to implement and maintain an SMS, however, the costs to a small company may be more difficult to absorb. In addition, in general, a company with larger towing vessels will incur more costs than one with smaller towing vessels. 5. What are the costs of drydocks? The costs range from $32,000 for smaller boats (800 hp) to $72,000 for the largest boats (6,000 hp). These costs account for the following: drydocking, remove and replace propeller, tailshaft runouts and inspection, remove and replace tailshaft, remove and replace rudder, micrometer readings, remove and replace rudder tube bearing, remove and replace cutlass bearing, hull gaugings, sea valves, sea strainers, remove and replace grid cooler, chemist certificate, tank inspections and gas free/storage. One company estimates its costs at between $2,500 and $3,000 per boat. This is just the fee to remove the vessel from the water. The labor costs for drydocking for this company are $60 per man-hour, which does not include paying for parts. 6. Do you expect the cost of drydocks to increase? The cost of drydocks will increase if there are more vessels requiring service. There are currently a limited numbers of drydocks and shipyards. There should not, however, be a dramatic increase in drydock demand due to the Subchapter M requirements. 7. What are the costs of third-party audits? Listed below are the costs associated with third-party audits of companies’ safety management systems and the time required to complete them, as broken down by size of company. Estimates are based on doing audits of 100% of required components, and testing as much data as necessary to determine levels of compliance with regulatory requirements and company procedures. Estimates include the cost of writing reports but do not include additional involvement in the corrective action process. Estimates also include consideration (i.e. overhead costs) for the company/organization invoicing for audits having to maintain compliance with quality management programs and provide training and oversight for auditors, as well as participate in verification of audit reports prior to submission to the audited company, work with customers to address concerns, if any, with the process and provide additional information to validate issues raised by auditors. Small Companies: 20 Towing Vessels – two-person auditing team, $4,000 to $6,000 per company (+ expenses), 2.0 to 3.0 days to complete As an example, the total costs for one company with 21 – 30 towing vessels in the past have ranged from $5,000 to $9,300, with travel and expenses amounting to an additional $2,500 to $4,000. (Costs may include third-party internal audits in addition to required third-party certification audits.) Listed below are the costs associated with towing vessel audits and the time required to complete them, as broken down by size of vessel. Figures are based on doing audits of 100% of regulatory requirements and testing as much data as necessary to determine levels of compliance with regulatory requirements and company procedures. At this time it is difficult to know if towing vessel audits will also require visits to the office to review records. Also, it is hard to know at this point in the regulatory process what impact the use of surveyors will have on the auditing process, and if the process used will result in the Coast Guard having sufficient data to determine whether or not a COI is to be issued, i.e. will an auditor also be involved in the process? Small Towing Vessels: 65’ – one auditor per towing vessel audit, $1,000 to $3,000 per towing vessel audit, 1.0 to 1.5 days to complete including report writing, but no corrective action involvement. 8. How many auditors will be required if every company must have a SMS? According to inland sources, approximately 175 to 325 more auditors will be needed throughout the inland waterways system. From the perspective of coastal operators, there will need to be at least 3 to 12 auditors at each port. Processes and Procedures for Towing Vessel Activities 1. Are fire, lifesaving, and other drills performed on towing vessels? All? Do you expect more drills? Yes. All towing vessels today are required to perform fire drills as well as lifesaving and other drills. There is a requirement to have proof of participation in required drills prior to a license being issued. Some companies have more of certain types of drills than others, according to their SMS. There is a possibility with the new regulations that the frequency of drills could be increased.

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2. How much time must a mariner spend filling the logbook? Log entries are made throughout the day on inland and coastal towing vessels, so to give an exact time frame on filling in the logs for many vessels would be an estimate. For SMS vessels, there is also time involved in filling out the training forms, fire drills, man overboard/abandon ship drills and other reports for recordkeeping. A vessel that is currently without an SMS will likely have to spend more time filling in logs compared to how much they spend today. 3. What is currently recorded in the logbook and will this change? Today, most inland and coastal towing vessels keep a log book for general ledgers of activities. Normally, this log book is filled out while the vessels are operating. The following is a list of normal log book entries for some companies operating under an SMS today; however, this is not a standardized list in all companies. For companies not under an SMS, then, this list could vary from company to company: • wheelman watch relief (time of change) • arrival time • draft and estimated speed • docking time (spot tow) • hose on time for barges • inspection company name • start loading/discharging time • finishing loading/discharging time • hose off time • release time • departure time • other times that may be important to your operation • details for all safety or other drills practiced • details for all steering, navigation, and communication testing performed • results of weekly/monthly testing of emergency lighting and power systems • fuel and lube data – including amounts transferred, if any • disciplinary action taken against any crewmembers • speed reductions to reduce wake damage • time of tow checks • posting of lookout, name and time of standing him down • any illness by a crewmember, including medical treatment • any personal injuries reported • where there are no injuries, make the notation, “No personal injuries reported today” • note name of every crewmember who arrives/departs the boat as crew with the place, time, manner and cause of departure • report of any death and cause of death • report of any collision, stranding or grounding

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• • • • • •

visitors and nature of visit times and places of all arrivals and departures of the vessel, including changes of river segments, locks, bridges, etc. intermittent operations such as drops or additions or barges, standby time, hire of tug, along with notations as to where, by whose orders, and for what purpose these operations were undertaken complete list of vessel crewmembers, including their ratings crew change times, and a listing of persons relieved and coming on duty report of any vessel damage

The information that harbor assist boats keep are the same as inland vessels, with the addition of the time alongside, time underway, time laid and at what dock. 4. What is the industry standard watch system? The most widely used watch system on inland vessels is a two-person watch system that is 6 hours on and 6 hours off for two shifts a day. This is called a square watch. The square watch system is normally used aboard vessels that are manned 24 hours a day with a live-aboard crew. However, there are a number of towing vessels that work local areas only that are on a 12 hour-on system. Harbor assist boats on the Gulf coast are, in general, on an on-demand watch system. East coast and West coast boats are more likely to be on a square watch system, with a three-watch system required under certain circumstances. 5. Are there costs for different watch systems? Normally on inland vessels, for either a square watch system or a two-watch system worked as a 12 hour-on, there is no additional cost. The cost and number of personnel required on a three-watch system, however, would be higher due to crew size, as many vessels are not equipped for the accommodations, including larger size Marine Sanitation Devices for larger crews, that a three-watch system requires. In general, a three-watch system requires a 50% increase in labor costs. For harbor assist boats, adding one wheelman to each vessel on a three-man crew would increase the costs by $75,000 to $120,000 per year in wages per watch/shift. Adding an additional deckhand per three-man boat would add costs by an average of $30,000 to $60,000 per year in wages per watch. 6. What are the industry’s practices in crew endurance? Are there adequate coaches, training, etc? The Coast Guard has encouraged all towing companies to implement the Crew Endurance Management System (CEMS), a system designed to identify and manage endurance risk factors in vessel operations. It is difficult to quantify the cost of implementing a CEMS program because the program is designed to be tailored to the

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specific risk factors that exist in a given company or on a given vessel. Companies implementing CEMS employ several tools to reduce endurance risks, including education, trained coaches, environmental and policy changes, light management, and schedule changes. Companies are encouraged to begin by addressing “low-hanging fruit,” making low-cost, high-payoff changes, and then continually assessing the need for further improvements in a cycle of continuous improvement. As part of its CEMS program, a company may choose to implement low- or no-cost policy changes or take on costly environmental changes such as sound-proofing. The Coast Guard does not dictate how a company addresses the endurance risks that are present in its operations. The cost of CEMS training has declined considerably over the last several years as the Coast Guard has instituted CEMS “expert” training. CEMS “experts” are certified to conduct training for CEMS coaches, making coaches training less expense and more widely available throughout the industry. While an increasing number of companies have begun to implement CEMS, mature CEMS programs are still a relative rarity in the industry, especially in the harbor services sector.

7. What would be the additional costs (computers, time, etc.) for new record keeping? For inland vessels, depending on the way a company will want to track their reports or record keeping, there might be added costs for computers onboard or for carbon copy forms for all drills and SMS record keeping. Some companies currently employ an electronic document control system (added computer) on each towing vessel, which requires maintenance, and an electronic Learning Management System (training records). Machinery and Equipment The Coast Guard can obtain numbers of vessels from public sources, but the areas of operations are not available. The Coast Guard requested the information below to help get a good picture of the diversity of uses of towing vessels. The working group was asked to estimate the number of vessels employed in each of the following areas of service. (For definitions of areas of operations, please see Appendix A at the end of the document.) Area of operation Limited Geographic Area Rivers Lakes, Bays & Sounds Limited Coastwise Coastwise Oceans

Number of vessels 40% 70% 60% 40% 40%

The estimates above are admittedly rough. For the purposes of defining areas of operation, it is important to keep in mind that there is considerable overlap between categories. For example, the same inland towing vessel may operate in rives, lakes bays

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and sounds, and limited geographic service. A coastal towing vessel may operate in lakes, bays and sounds, coastwise, and ocean service. . Hourly rates The Coast Guard will obtain from other sources estimates of how long various installations of equipment will take. The agency requested from the EAWG the ranges of hourly rates in the area for the labor classes listed below: Louisiana and Kentucky (Yearly Rates) Labor class Electrician Welder Pipefitter/metal worker Other

Minimum rate Average Rate $20,000 $36,933 $20,000 $38,466 $25,000 $35,400

Maximum rate $56,000 $59,000 $44,000

Georgia (Per Hour) Labor class Electrician Welder Pipefitter/metal worker Other

Minimum rate

Average Rate $25 $18 $18

Maximum rate

Compliance with selected draft requirements The Coast Guard requested information on percentages of the fleet that already comply with specified procedures or have specified equipment. The EAWG was told that responses in terms of the nearest 10% are acceptable. Part 140 – Operations Emergency Drills and Training: Section 325 would require annual training for emergencies, firefighting, and lifesaving equipment. The section would also require that information on the drills and training be recorded. What would be the approximate annual costs for the associated administrative and recordkeeping to implement the required drills and training? Administrative costs, including the costs for personnel, benefits, hardware and software, should be less than $1,000 per vessel.

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Evaluation of hazards and implementations of controls: Section 405(a), would require that “Each vessel and its operations must be evaluated for chemical, biological, ergonomic, and physical hazards, and sufficient control measures must be implemented to minimize recognized hazardous conditions.” What percentage of the vessels are the evaluations of hazards taken? If the evaluation finds hazardous conditions, what percentage of the vessels implement control measures? The responses below are not based on area of operation as much as they are on cargo hazards. In general, hazard evaluations are tasks that virtually every vessel operator routinely performs. For example, one company has 100% of its vessels evaluated for physical hazards which include ergonomic adjustments under a vessel safety inspection program managed by a safety assistant. It does not evaluate chemical and biological hazards as a standard item. All of its vessels implement operational changes based on safety inspections within a specified time period; the aafety assistant also performs a follow-up procedure to determine if violations to safety policy have been corrected or eliminated. Another company currently implements a Job Safety Analysis program to identify and mitigate any hazards before commencing a job or activity.

Area of operation Limited Geographic Area Rivers Lakes, Bays & Sounds Limited Coastwise Coastwise Oceans

Percentage of vessels that conduct evaluations of hazards

Percentage of vessels that implement control measures

75-100

75-100

100 100

100 100

Part 141 – Lifesaving Immersion suits: Section 141.350 requires that vessels that operate above 32 degrees North latitude carry immersions suits. For vessels that operate above 32 degrees North latitude, what percentage of the vessels carry immersions suits for every person onboard by area of operation? Immersion suits/ survival suits are the norm for all vessels on coastwise and ocean voyages. For river vessels, immersion suits are not typically employed, as most companies instead have procedures calling for evacuating the crew to shore or to the two in the event of a vessel emergency requiring abandonment of the towing vessel.

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Area of operation

Percentage of vessels that have immersion suits

Limited Geographic Area Rivers Lakes, Bays & Sounds Limited Coastwise Coastwise Oceans

5-20

100 100

Part 142 – Firefighting Insulation for engine exhaust ducts and galley exhaust ducts: Section 215(c) world require that engine exhaust ducts and galley exhaust ducts must be insulated if they are less than 18 inches away from combustibles. Coverage What percentage of the vessels has insulation for exhaust ducts and galley exhaust ducts less than 18 inches away from combustibles? What percentage of vessels would not require insulation?

Area of operation

Limited Geographic Area Rivers Lakes, Bays & Sounds Limited Coastwise Coastwise Oceans

Percentage of vessels that has insulation Percentage of vessels for exhaust ducts and galley exhaust that would not require ducts less than 18 inches insulation 0-10

40-100

Costs What are the cost estimates to insulate the ducts?

Cost

Estimated cost to insulate ducts

Purchase cost Installation: Cost to install Time to install

Estimated cost to insulate ducts $5,000 to $30,000

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Can installation occur while vessel is in operation? No. Remote starter for fire pump: Section 325(a)(2) would require that if you have a fixed fire-pump it must have a remote starter. What percentage of the vessels, by area of operation, complies with these requirements? If an area only has portable fire-pumps then please enter “N/A.” The Coast Guard currently requires that all towing vessels have a remote fire pump starter. Approximately 80% of inland vessels and all coastwise/ocean towing vessels are so equipped.

Area of operation

Limited Geographic Area Rivers Lakes, Bays & Sounds Limited Coastwise Coastwise Oceans

Percentage of vessels with fixed fire-pumps and remote starters 80-100

100 100

Part 143 -- Machinery and Electrical Fuel system: Section 315 would specify the fuel system requirements. What percentage of the vessels meets these requirements? Almost all vessels have emergency fuel shutoffs. Area of operation

Limited Geographic Area Rivers Lakes, Bays & Sounds Limited Coastwise Coastwise Oceans

Percentage of vessels that meet fuel system requirements 100 100 100 100 100

Of those do not meet 100 percent fuel system requirements, what percentage do they meet?

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Electrical system installations: Section 325(b) would require that terminations and connections take place in junction boxes and that appropriate UL label are on the wires and cables. What percentage of vessels have evaluations of hazards conducted? Area of operation Limited Geographic Area Rivers Lakes, Bays & Sounds Limited Coastwise Coastwise Oceans

Percentage of vessels that conduct hazards evaluations 100 75-100

100 100 Part 144 -- Construction and Arrangement

Ventilation for accommodations: Section 355(c) would require that “Means must be provided for stopping each fan in a ventilation system serving machinery spaces.” What percentage of the vessels has a ventilation shutoff? Area of operation Limited Geographic Area Rivers Lakes, Bays & Sounds Limited Coastwise Coastwise Oceans

Percentage of vessels that has a ventilation shutoff 100 50-100

Third-party organizations 1. What is the current number of third-party auditors and surveyors? There are 95 entities that conduct RCP audits. We expect that close to half of these are not actively participating in the third-party auditing process, and that the remaining auditors are working at the process less than full time. There are 60 auditors that conduct ISM and RCP audits, and 20 that conduct DCA audits. 2. How many individuals are cross-certified by auditing organizations for auditing and by other organizations for surveying? Approximately 100 auditors could become qualified as surveyors under the proposed program. Barge surveyors typically used in the towing industry may not necessarily have experience and/or backgrounds in towing vessel components and processes. Some auditing training will be helpful if the surveyors need to interact with the auditing

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process and/or provide documentation suitable for providing an audit trail and conclusions needed by the Coast Guard for decision-making concerning Certificates of Inspection (COIs). ABS has approximately 200 auditors and surveyors, of which approximately 60 are cross-trained as auditor/surveyor. 3. How many of the above are exclusively employed in auditing? It is hard to determine an exact number, but it is expected that approximately 50 RCP certified auditors achieved certification in order to improve their own company’s program rather than conduct third-party audits. Otherwise, most of the other certified auditors are employed as accident investigators, traditional surveyors, safety trainers, etc. Approximately 15% of the ABS group are employed full-time as auditors. 4. What is the number of third-party auditors required under Subchapter “M” if every company must have a SMS? If one were to assume that approximately 50% of the current 3600 companies (USCG’s number) utilizing towing vessels are operating some level of safety management system, another 1000 to 2000 companies might be required to adapt to having an SMS in order to comply with Subchapter M. Between 175 and 325 additional auditors may be required to handle the additional workload for Subchapter M compliance. 5. What is the current audit frequency for RCP? Third-party audits of the company management system and a representative portion of the towing vessels are required every 3 years. 6. What is the current audit frequency for ISM? Third-party audits of the company management system are required annually. All vessels are required to be audited every 2.5 years. 7. How much time is currently required to audit towing vessels? ABS auditors apparently spend about 4 hours per towing vessel on the RCP portion of their work, which is understood to be time spent in addition to the other work being done, including ISM audits, etc. 8. How much time is currently required to audit SMS? ABS auditors spend between a half day and a full day on management audits of the RCP SMS. This is understood to be time spent in addition to the time required for other work, such as an ISM audit.

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RCP auditors spend between a full day and two full days on RCP management audits, depending on the complexity of the system and the methods utilized by the individual auditor. 9. How much time is currently required to audit equipment systems? Approximately half of the time spent on the towing vessel audit involves equipment and equipment systems. 10. What are the qualifications for Coast Guard recognized auditors? For ISM auditors, the qualifications are 5 years experience in maritime industry, an ISM training course, an ISO 9001 Lead auditor course, and the observation of 5 audits being conducted. 11. What are the costs to get certified? The cost of ISM and ISO courses are $3,000 plus expenses (roughly $2,000 for travel), with 3 weeks of training. The training includes salaries. 12. For third-party organizations, what will it take to meet the draft regulations? This will be determined by the Coast Guard.

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APPENDIX A Description of the fleet In the compliance section the Coast Guard is asking for the percentages of the vessels by area of operation that meet specified draft requirements. The definitions of the areas of operation are: Limited geographic area means a local area of operation, usually within a single harbor or port. The local Captain of the Port (COTP) determines the definition of local geographic area for each zone. Rivers: means any river, canal, or other similar body of water designated by the Officer in Charge, Marine Inspection. Lakes, bays, and sounds: means a route on any of the following waters: (1) A lake other than the Great Lakes; (2) A bay; (3) A sound; or (4) Such other similar waters as may be designated by a Coast Guard District Commander. Limited coastwise: means a route that is not more than 20 nautical miles from a harbor of safe refuge. Coastwise: means a route that is not more than 20 nautical miles offshore on any of the following waters: (1) Any ocean; (2) The Gulf of Mexico; (3) The Caribbean Sea; (4) The Bering Sea; (5) The Gulf of Alaska; or (6) Such other similar waters as may be designated by a Coast Guard District Commander. Oceans: means a route that is more than 20 nautical miles offshore on any of the following waters: (1) Any ocean; (2) The Gulf of Mexico; (3) The Caribbean Sea; (4) The Bering Sea; (5) The Gulf of Alaska; or (6) Such other similar waters as may be designated by a Coast Guard District Commander.