Successful Coast Guard Inspections in the Shipyard
As complicated as shipyard visits can be, the last thing vessel owner/operators want to encounter is problems with regulatory personnel, such as the Coast Guard or a classification society. The best way to avoid costly delays and compliance errors is to know what to expect, be prepared for the inspections, and know how to respond to inspectors.
The role of the Coast Guard marine inspector is often misunderstood. Whether you are dealing with a barge or a large ship, almost every aspect of a certificated vessel has regulations that apply to it. Vessel plans are approved prior to new construction and vessels are inspected to ensure that they are constructed in accordance with those approved plans. The role of the marine inspector, regarding repairs, is to ensure that the repairs are consistent with the approved plans throughout the life of the vessel, which is why the phrase "replace as original" is often used. The marine inspector in the shipyard does not have the authority to approve modifications that are not "as original" or that are inconsistent with current rules and regulations.
A common mistake that some vessel companies make is forgetting to notify the Coast Guard when a certificated vessel is being repaired, or is going on drydock. It's a requirement to notify the Coast Guard so that they can approve repairs and witness nondestructive testing (NDT). The following personal experience illustrates many of the problems that can arise when shipyard visits are not handled correctly. As a Coast Guard marine inspector years ago, I was called out to witness a "repair check" on a tank barge. We weren't given much information and didn't know what to expect when we got to the shipyard. To make sure that we got in and out of there as fast as possible, the tanks were already pressured up when we arrived and were ready for testing.
The test went fairly well but when I realized I was there to witness the NDT of all the welds on one-third of the entire barge's tank tops, I started asking questions about the extent of the repairs, and the nature and cause of the damage. I was told that the entire tank top, and some of the adjacent tank tops, had imploded during discharge due to a seized up pressure/ vacuum valve. The barge had subsequently been put in the shipyard and the entire tank top had been replaced along with portions of the adjacent tank tops and all associated deck equipment. The barge had been in the shipyard for quite some time and this was the first the Coast Guard was hearing about it. Since we hadn't been there to inspect the repairs in progress, we did what we could after the fact by checking if the shipyard was using approved welding procedures and the proper electrodes.
As the inspection progressed, I found the welder who had done the majority of the welding and asked to see his welder's qualifications. As it turned out, he had none. To make matters worse, in attempting some "damage control," the shipyard sent the same unqualified welder off to the welding school to try and get qualified, but he couldn't pass the qualification, even after three attempts. The vessel company was left with two choices: gouge and re-weld the entire job, or x-ray the welds. Obviously they chose the x-rays. After a great deal of time, aggravation and money, the repairs passed inspection and the barge was on its way. This was an unfortunate case, which illustrates what can go wrong, but also how the inspection process is supposed to work. Had that unqualified welder not made good full penetration welds and the barge broke and oil spilled as a result, there would have been a great deal more time, money and aggravation for all involved parties.
Often problems arise during shipyard inspections due to lack of preparation. Many vessel representatives find it futile to prepare for the Coast Guard so they just call the inspectors out and hope for a comprehensive work list. Coast Guard inspectors are not there to survey the vessel. That should be done beforehand. The Coast Guard is responsible for inspecting the vessel to ensure that it is in compliance with all regulations. If a vessel is determined to be "not ready for inspection," many Coast Guard inspectors will walk off the job. Try to prepare as much as possible before the Coast Guard comes out. If no surveyor with Coast Guard inspection expertise is available, refer to guidance documents such as the "Steel NVIC" or local Officer in Charge of Marine Inspection (OCMI) guidance such as the "Inland Barge Repair Guide" in the New Orleans zone.
When it comes to internal exams, make sure the space is as dry as can be and that the marine chemist's certificate is not voided by paying attention to all the notes and written instructions. Coast Guard inspectors have no leeway when it comes to entering confined spaces.
Finally, each vessel company must choose which battles to fight. But if you feel a Coast Guard inspector is making an incorrect or unfair decision, you can challenge it. The best way to approach it is to ask the inspector to explain the basis for his decision and what written guidance he is basing it on. If you are still not satisfied and are unable to convince him that what you propose is allowable in accordance with written regulations and guidance, then you should respectfully agree to disagree and mention that you want to discuss it further with that inspector's supervisor. This is the industry's right and it should be exercised. Just within the last few months the Commandant of the Coast Guard published guidance to all Coast Guard personnel in ALCOAST 108/08 which reads:
"The exercise of appeal is a right we strongly support. Questions, differences of professional opinion, and appeals are normal and improve the conduct of business. We must be as accepting of these as praise. Attempt to resolve problems at the lowest level possible and be resourceful in doing so."
About the Author:
Kevin Gilheany is a maritime industry consultant and a retired Coast Guard marine inspector. His company, Maritime Compliance International, LLC, is on the WEB at: http://www.maritimecomplianceinternational.com. He can be reached at firstname.lastname@example.org.
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