Proceedings magazine is a communication tool for the Coast Guard's Marine Safety & Security Council. Each quarterly magazine focuses on a specific theme of interest to the marine industry.
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84 Proceedings Fall 2015 www.uscg.mil/proceedings regulations regarding vessel design, and to develop accept- able design criteria to fll those gaps. Also in 2012, the IMO Subcommittee on Bulk Liquids and Gases was in the midst of developing the IGF Code and recognized the need to develop associated training require- ments in support of the code, so members requested that the Subcommittee on Standards, Training and Watchkeeping begin work in this area. The ensuing discussions identifed a need for mandatory training requirements for crew serving on ships fueled by gas or low- fashpoint fuels. Furthermore, the subcommittee determined that until such time as mandatory requirements could enter into force, there was a need to develop interim guidance to: • ensure the safe transition of existing, experienced mari- ners into the new operations; • ensure the availability of mariners trained to operate these vessels; • fll the gap until the Standards of Training, Certifca- tion and Watchkeeping (STCW) amendments came into force with the IGF Code. The United States led the effort to develop the mandatory training requirements as well as the interim guidance, as the MERPAC recommendations became the basis for the U.S. positions at the IMO. The end product from this initia- tive was a set of amendments to the STCW Convention and Code contained in Chapter V related to the IGF Code. These amendments were approved in June 2015 and will come into force concurrently with the IGF Code at a future date. Furthermore, interim guidance was approved in November 2014 for immediate implementation until the IGF Code and the above-mentioned training requirements come into force. 1 Current U.S. Training Policy In February 2015, the Coast Guard published CG-OES Policy Letter No. 01-15, "Guidelines for Liquefed Natural Gas Fuel Transfer Operations and Training of Personnel on Vessels Using Natural Gas as Fuel." Enclosure 3 to this policy letter provides training guidance and recommends the level of competence necessary for the safe operation of ships using gases and low-fashpoint fuels. Specific training: Mariners employed on these ves- sels should receive appropriate training on the risks and emergency procedures associated with gases or other low- fashpoint fuels in accordance with their duties and respon- sibilities. On that basis, the training levels include: • advanced training for vessels using gases or low- fashpoint fuels. This is applicable to any person with immediate responsibility for the fuel and fuel systems on these vessels. Mariners who are qualifed and certi- fed for service on liquefed gas tankers as tankerman PIC (LG) or tankerman engineer (LG) and who have the recommended sea service meet the general training recommendations. • basic training for vessels using gases or low-fashpoint fuels. This is applicable to mariners with duties associ- ated with using, or in emergency response to, the fuel aboard these vessels. Mariners who are qualifed and certifed as tankerman PIC (LG), tankerman engineer (LG), or tankerman assistant (LG) meet the general training requirements. Familiarization training: Mariners on U.S. vessels must comply with the existing requirements in 46 CFR 15.405 (familiarity with vessel characteristics) and 46 CFR 15.1105 (STCW — familiarization and basic training) before assum- ing their duties. This familiarization is essential, as the spe- cifc training described above is general in nature. Mariners and any person aboard vessels using gases or low- fashpoint fuels need job-, ship-, and fuel-specific familiarization training. For the non-mariners, this familiarization should specify any additional information that would affect their onboard safety. Mariners on foreign-fagged vessels operating in U.S. waters should receive the training contained in the IMO guid- ance STCW.7/Circ.23 as well as the familiarization train- ing required in STCW Regulations I/14, "Responsibilities of companies." 2 Future Considerations Throughout the policy development process, stakeholders recognized that the ships designed or modifed to use these alternative fuels have a great deal in common with vessels that use conventional fuels. The differences lie in the fuel Liquefed Gas Bunkering There are no mariner qualifcation changes for those sailing aboard those classes of tank vessels, including liquefed gas carriers, that currently burn their cargo as fuel. As bunkering vessels are considered to be tank ships and tank barges, the training and manning requirements are already in place. For additional information regarding bunkering vessels using gases and low-fashpoint fuels, consult CG-OES Policy Letter 02-15, available at www.uscg.mil/hq/cg5/ cg522/cg5222/PolicyLetters.asp.