Proceedings Of The Marine

SPR 2015

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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39 Spring 2015 Proceedings oil or hazardous materials, commercial divers must meet 29 CFR 1910.120 training and operational requirement stan- dards. 3 Additionally, the National Oceanic and Atmospheric Administration (NOAA) states SCUBA diving is not appro- priate where there is a risk of oil or toxic chemical inges- tion. 4 For contaminated water diving, the National Research Council, U.S. Environmental Protection Agency, NOAA, the Association of Diving Contractors International, and Inter- national Marine Contractors Association have published guidance and protocols. 5 Emergency Towing The Coast Guard's salvage regulations require applicable vessel owners and operators to ensure emergency towing vessels have the proper characteristics, horsepower, and bollard pull to tow their vessels in any condition of loading, and are also capable of operating in winds up to 40 knots. Like the rigging inspections and standards discussed ear- lier, personnel should thoroughly inspect emergency tow- ing gear prior to operations and incorporate a reasonable margin of safety into the calculation. It should be noted, load cells, correctly installed and calibrated, are the only way to accurately measure the tension in a towing system. Stranding salvage often involves refoat attempts with tow- ing vessels and ground tackle. Again, responders should measure stresses on the system to prevent a catastrophic failure. Marine Firefghting In the case of an onboard fire, after the ship's crew has exhausted attempts to control the fre, it will fall to the pro- fessional salvor to lead onboard marine frefghting opera- tions. The Coast Guard's salvage and marine frefghting regulations defne expected marine frefghting response timelines for vessels at the pier, near shore, and offshore. A professional salvor can not only bring external frefghting systems and teams, salvors can also bring dewatering pumps, a working knowledge of shipboard systems, and naval architects to analyze the ship's stability and structural integrity. Without the comprehensive suite of maritime services pro- vided by a professional salvor, the end result of a marine frefghting response is often inadequate and costly, in both safety and property. In sum, for high-risk marine frefghting incidents, professional salvors should be activated immedi- ately and Coast Guard incident commanders should call upon the NSF and the Coast Guard Marine Safety Center Salvage Engineering Response Team to support assessment and response efforts. Command and Control National Strike Force members have served in leadership positions during many of the nation's largest and most high- profle incidents. Experts in the Incident Command System, members have managed operations during numerous sal- vage and subsea operations. Regarding salvage and marine frefghting operations, since marine casualty operations often require time-critical deci- sions, the unifed command should work directly with the salvor during the initial stages of the response operation to ensure alignment on initial actions. Issues can arise when the salvor is positioned below an operations section chief who has little to no marine casualty response experience, which is more often than not in today's all-hazard response world. Ongoing Training Finally, to prepare for salvage and marine frefghting opera- tions, Coast Guard responders should consider attending additional training, such as the American Salvage Asso- ciation's salvage course. Members of the American Salvage Association also offer industry training programs for indi- vidual Coast Guard members. Additionally, area commit- tees should establish a salvage and marine firefighting workgroup to coordinate training, exercises, and conceptual incident action plans for future operations. About the author: Mr. Jim Elliott served previously as a National Strike Force response off- cer. Today, he is responsible for managing worldwide salvage and emergency response operations for T&T Salvage, and he is also a Type 1 incident com- mander and federal on-scene coordinator. Mr. Elliott holds a B.S. in envi- ronment management, a master of environmental policy, and an M.A. in national security and strategic studies. Endnotes: 1. While many crane and derrick barges are "uninspected" or do not require a COI, it should be noted these foating assets are regulated under the Occupational Safety and Health Administration (OSHA). For example, 29 CFR 1926.1437, pro- vides a list of requirements for pre-use, monthly, annual, and quadrennial inspec- tion requirements for foating crane and derricks. For example, the lifting assets should have certifcates for annual inspections and there should be records of these various inspections, including survey reports of the internal barge inspec- tions required every four years for Coast Guard "uninspected" barges. 2. Federal Register, Department of Homeland Security, Coast Guard 33 CFR 155 Sal- vage and Marine Firefghting Requirements; Vessel Response Plans for Oil; Final Rule; December 31, 2008, and Federal Register, Department of Homeland Security, 33 CFR 151, 155, and 160; Nontank Vessel Response Plans and Other Response Plan Requirements; Final Rule, 2013. 3. Occupational Safety and Health Administration. Commercial Diving Regulations (29 CFR Subpart T); Hazardous Waste Operations and Emergency Response (29 CFR 1910.120); and Training Marine Oil Spill Response Workers under OSHA's Hazardous Waste Operations and Emergency Response Standards. OSHA 3172, 2001. 4. NOAA Diving Manual: Diving for Science and Technology. U.S. National Oceanic and Atmospheric Administration, 4 th Edition, Revised, September 1, 2010. 5. National Research Council. Spills of Nonfoating Oils: Risk and Response, National Academy Press, Washington, D.C., 1999. Association of Diving Contractor Interna- tional. Consensus Standards for Commercial Diving Operation; Sixth Edition revised, 2014. International Marine Contractors Association, Diving in Contaminated Waters, IMCA D 021.

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