AMAZING GRACE

Each towing vessel must be operated in compliance with Parts 151, 155, and 156, of 33 CFR, as applicable. No person may operate a non-oceangoing ship of 100 gross tons and above that is fitted with main or auxiliary machinery spaces in the navigable waters of the United States unless: The ship has a stop valve for each outlet required by this section. MI discovered that the overboard discharge valve for the bilge system was inoperable and was rattling loose. Make repairs to the satisfaction of the attending MI. 46 CFR 140.655 705C

Individual circuit breakers on switchboards and distribution panels must be labeled with a description of the loads they serve. MI found that the ER panel was not properly labeled. Make repairs to the satisfaction of the attending MI. 46 CFR 143.400

Emergency lighting must be provided for all internal crew working and living areas. Emergency lighting sources must provide for sufficient illumination under emergency conditions to facilitate egress from each space. MI found that E light was not working. Make repairs to the satisfaction of the attending MI.

Towing vessels more than 65 feet in length must use navigation lights that meet UL 1104 (incorporated by reference, see § 136.112 of this subchapter) or other standards accepted by the Coast Guard. MI discovered that the Navigational lights were not operating properly. Make repairs to the satisfaction of the attending MI.

If a dedicated storage cabinet is provided it must be secured to the vessel so that it does not move. MI found that the oil tank to be loose and not secured to the vessel in anyway. Make repairs to the satisfaction of the attending MI.

An exposed hazard such as gears and rotating machinery, must be protected by a cover, guard or rail. MI discovered that there was no protective grating over the steering gear. Make repairs to the satisfaction of the attending MI. 46 CFR 144.820

Each lifejacket must be marked: In block capital letters with the name of the vessel. MI inspected life jackets in galley were not marked with vessels name. Make repairs to the satisfaction of the attending MI. 46 CFR 141.340

Stowage positions for life jackets stowed in a berthing space or stateroom and all life jacket containers must be marked in block capital letters and numbers with the minimum quantity, identity, and, if sizes other than adult or universal sizes are used on the vessel, the size of the life jackets stowed inside the container. MI witnessed the life jackets stored the galley were not marked on quantity and location. Make repairs to the satisfaction of the attending MI. 46 CFR 141.340

To stop the flow of fuel in the event of a fire or break in the fuel line, a remote fuel shutoff valve must be fitted on any fuel line that supplies fuel directly to a propulsion engine or generator prime mover. Shutoff valve does not close fully.

Towing vessels must be equipped with the following equipment, as applicable to the area of operation: Illuminated magnetic compass or an illuminated swing-meter (Western Rivers vessels only). The compass or swing-meter must be readable from each operating station. Vessel does not have a compass.

Rails or equivalent protection must be installed near the periphery of all decks accessible to crew. Rail posts are rusted at deck joints excessively.

Search light, controllable from the vessel's operating station and capable of illuminating objects at a distance of at least two times the length of the tow. Starboard search light does not illuminate.

The hose must be a lined commercial fire hose 15 meters (50 feet) in length, at least 40 millimeters (1.5 inches) in diameter, and fitted with a nozzle made of corrosion-resistant material capable of providing a solid stream and a spray pattern. Starboard fire hose nozzle is cracked and leaking water.

If a dedicated storage cabinet is provided it must be secured to the vessel so that it does not move. Locker is not secured to the vessel.

Each towing vessel must be equipped with navigation lights, shapes, and sound signals in accordance with the International Regulations for Prevention of Collisions at Sea (COLREGS) or 33 CFR part 84 as appropriate to its area of operation. Mast light does not illuminate.

All bilges and void spaces are kept free from accumulation of combustible and flammable materials and liquids insofar as practicable. Bilge contains excess oily water.

Emergency lighting must be provided for all internal crew working and living areas. Emergency lighting is not present in berthing or heads.

Each lifebuoy with a floating electric water light must have a lanyard of at least 910 millimeters (3 feet) in length, but not more than 1,830 millimeters (6 feet), securing the water light around the body of the lifebuoy. Water light line is shorter than 3 feet.

Electrical systems and equipment must function properly and minimize system failures and fire and shock hazards. Electrical junction boxes in engine room and above bridge do not have covers.

Each towing vessel must be maintained and operated so as to minimize fire hazards. The fuel oil filter on both generators were missing the heat shield. Repair to the satisfaction of the attending Marine Inspector. 46 CFR 142.220

Failure to meet Certificate of Inspection posting requirements. All 3 pages of COI were together in one picture frame. Each page of the COI must be visible, so each page should be in it's own frame and posted in a conspicuous place on the vessel.

Inspections and tests of lifesaving equipment must be recorded in the TVR or official logbook. There were no records on board of lifesaving equipment maintenance or tests.

Each towing vessel must be maintained and operated so as to minimize fire hazards. The fuel oil filter on both generators were missing the heat shield. Repair to the satisfaction of the attending Marine Inspector.

Electrical systems and equipment must function properly and minimize system failures and fire and shock hazards. Electrical breaker panel outside of deckhand stateroom was missing labels. Label panel to the satisfaction of the Marine Inspector. 46 CFR 143.400(a)

Each towing vessel must have a reliable means to provide notification when an emergency condition exists or an essential system develops problems that require attention. Bridge alarm panel and Engine Room alarm panel was missing labels and some of the lights are burnt/inoperable. Label panel properly and fix lights to the satisfaction of the Marine Inspector. 46 CFR 137.200

Each life jacket must have a life jacket light approved under approval series 161.012 or 161.112 securely attached to the front shoulder area of the life jacket. Each life jacket must have a whistle firmly secured by a cord to the life jacket. Life jacket in deckhand stateroom is missing light and whistle. Attach appropriate light and whistle to life jacket to the satisfaction of the Marine Inspector. 46 CFR 141.340(g)(1) and 46 CFR 141.340(g)(2)

Sufficient lighting suitable for the marine environment must be provided within crew working and living areas. Multiple external deck lighting had cracked housing or lenses. Not suitable for marine environment and should be replaced to the satisfaction of the Marine Inspector. 46 CFR 143.410(a)

The Master must ensure that all lifesaving equipment is properly maintained and ready for use at all times. The life jacket located in skiff is dry-rotted and not ready for use. Replace life jacket to the satisfaction of the Marine Inspector. 46 CFR 141.230

Essential systems or equipment must be regularly tested and examined. Tests and examinations must verify that the system or equipment functions as designed. If a component is found unsatisfactory, it must be repaired or replaced. Test and examination procedures must be in accordance with manufacturer's instructions or the Towing Safety Management System (TSMS) applicable to the vessel, if the vessel has a TSMS. The fire pump pressure was inadequate. Repair to the satisfaction of the Marine Inspector. 46 CFR 143.245(a)

Machinery and electrical systems must be designed and maintained to provide for safe operation of the towing vessel and safety of persons on board under normal operation and emergency conditions. There was a raw water leak on the port main diesel engine, and the flexible hose on the steering great actuator has excessive deterioration. Repair to ensure proper operation of the systems, to the satisfaction of the Marine Inspector. 46 CFR 143.205 (a)

There must be an installed or portable bilge pump for emergency dewatering. Any portable pump must have sufficient hose length and pumping capability. All installed bilge piping must have a check/foot valve in each bilge suction that prevents unintended back flooding through bilge piping. Number 1 bilge pump shaft seal is compromised. Repair to ensure proper operation of the systems to the satisfaction of the Marine Inspector. 46 CFR 143.275

The Owner, managing operator, or master must ensure that all persons on board a towing vessel comply with the health and safety plan. The donning placard for life jackets throughout the vessel are not correct. This is a safety hazard and the appropriate placards should be used to ensure the safety of crew members. Replace placards to the satisfaction of the Marine Inspector. 46 CFR 140.500(b)

Each towing vessel must be equipped with an industrial type first aid cabinet or kit, appropriate to the size of the crew and operating conditions. Observed that multiple items in the First Aid kits that were expired. 46 CFR 140.435

The VHF-FM radio must be installed at each operating station and connected to a functioning battery backup, and all towing vessels must have at least one properly installed VHF in addition. There was no battery backup for communications on board in the event of a loss of power.

"The TPO and the owner or managing operator may be required to explain or otherwise demonstrate areas of the TSMS to the Coast Guard if there is evidence that a TSMS, for which a TSMS certificate was issued, is not in compliance with the provisions of this part. The Coast Guard may require a third party’s attendance at the vessel or the office of the owner or managing operator for this purpose." As a result of the USCG inspection on 26JUN2019, our findings indicated clear grounds exist to request the TPO Meridian Global Consulting LLC to conduct an external management audit on American Tugs Inc, as evident from: 1) a direct discrepancy between cleared items on the 31JAN2019 vessel survey with similar deficiencies found during the 11APR2019 vessel audit, and 2) on board deficiencies identified by the USCG on 26JUN2019 indicated a serious failure/lack of effectiveness of the company's safety management system. During the management audit, particular attention should be given to proper corrective action under the "Observations & Non-conformities" section within their Safety Management Manual. 46 CFR 138.510

To stop the flow of fuel in the event of a fire or break in the fuel line, a remote fuel shutoff valve must be fitted on any fuel line that supplies fuel directly to a propulsion engine or generator prime mover. The valve must be operable from a safe place outside the space where the valve is installed. The remote shutoff valve was frozen, & unable to be closed in the event of an emergency, unresolved since id'd by TPO on Apr 11, 2019. 46 CFR 143.260(d)

A fixed fire pump must be capable of being energized remotely from a safe place outside the engine room and at the pump. The fire pump was not capable of being actuated from the pump, no local controls present. 46 CFR 142.325(a)(2)

Each towing vessel must have either a self-priming, power-driven, fixed fire pump, a fire main, and hoses and nozzles in accordance with paragraphs (a) through (d) of this section The hose must be a lined commercial fire hose 15 meters (50 feet) in length, at least 40 millimeters (1.5 inches) in diameter, and fitted with a nozzle made of corrosion-resistant material capable of providing a solid stream and a spray pattern. The fire station nozzle was not capable of providing a sufficient solid stream pattern needed to extinguish onboard fires. 46 CFR 142.325(d)

INCORRECT NAME AND HAILING PORT ON BOW, STERN OF VSL.

FORWARD MASTHEAD LIGHT MUST BE 1 METER ABOVE RUNNING LIGHTS.

INCOMPLETE OIL TRANSFER PROCEDURES.

ONE TOILET ONBOARD HAD DIRECT DISCHARGE CAPABILITY.