LULU HAMILTON

Towing vessels with a Towing Safety Management System (TSMS) must be operated in accordance with the TSMS applicable to the vessel. During the initial inspection for certification, the vessel did not have a crew on board to demonstrate implementation of the vessel's TSMS. Outstanding items which still need to be verified include: TSMS is on board and available addressing emergency duties and procedures, crew member safety orientations, records of drills and training, vessel logs and navigation assessments, marine casualty reporting procedures, enrollment in crew member random drug testing program, lifesaving and firefighting inspection records, crew member vessel familiarity, and MMC check. Additionally, installation of charts and publications on board and the installation of forward tow wires/lines need to be verified. Prior to operations, the vessel's crew is to demonstrate the implementation of TSMS and operational procedures to the satisfaction of the attending Coast Guard inspector. Demonstration shall include the witnessing of fire and man overboard drills while underway and the satisfactory operation of associated essential systems. Vessel is allowed a one-time transit from FMT Shipyard, Harvey, LA to Conley Marine Services, Harvey, LA. 46 CFR 140.205 705c

Vessel audits. An external audit must be conducted prior to the issuance of the initial COI for vessels subject to an owner or managing operator's TSMS that have been owned or operated for six (6) or more months prior to receiving the initial COI. Vessel to provide objective evidence of a satisfactory external audit conducted by the cognizant third party organization within six (6) months of issuance of the initial COI. Failure to complete and provide evidence of this audit will result in the vessel being reverted to the Coast Guard inspection option, suspension of vessel operations, or COI revocation, as determined by the OCMI. 46 CFR 138.315(2)(b) 705c