22/02/2022
PRE-ARRIVAL TESTS, 33 CFR 164.25(a): The tests listed in §164.25 are required to be conducted no more than twelve (12) hours prior to entering U.S. navigable waters and logged in the vessel’s logbook. A log entry of “Test conducted in accordance with 33 CFR 164.25” is not acceptable unless used in conjunction with a check off sheet.
EMERGENCY STEERING DRILL, 33 CFR 164.25(d): An emergency steering drill as specified at http://www.ecfr.gov must be conducted within 48 hours prior to entry and logged in the vessel’s logbook, unless the drill is conducted and logged on a regular basis at least once every three months. This drill must have a separate log entry from the equipment test unless the drill is part of the 12-hour pre-arrival check-off list.
REPORTING NON-OPERATING NAVIGATION EQUIPMENT
REFERENCE: Reporting Non-Operating Equipment 33 CFR 164.53
POLICY: Upon receiving a written request, the COTP may authorize a deviation from a specific rule in 33 CFR Part 164.
If the vessel’s radar, radio navigation receivers, gyrocompass, echo depth sounding device, AIS, Electronic Position Fixing Device, ARPA, or primary steering gear is inoperable, it must be reported to the COTP as soon as possible. Use the Letter of Deviation Application Form located at Homeport to request a Letter of Deviation (LOD).
LODs are issued only for equipment identified in the following table because the COTP places certain restrictions or provisions on vessels when any of the listed equipment is inoperative.
An LOD is not a detention; however, the vessel must request permission to move within or depart the port if the equipment is not repaired.
If equipment becomes inoperable during a voyage, a report to the COTP must be submitted prior to arrival.
RESTRICTIONS THAT MAY BE PLACED ON A VESSEL’S OPERATION:
A vessel greater than 1,600 gross tons with no operable radar(s): The COTP may allow a vessel to enter port during daylight hours only, provided there are at least three (3) miles of visibility and you have suitable tug assistance. While entering port, an additional licensed officer is required on the bridge to assist in navigation as well as a bow watchstander.Vessels greater than 10,000 gross tons with one of two required Marine Radars inoperative: The COTP may allow a vessel to enter port during daylight hours only, provided there are at least three (3) miles of visibility, a second licensed officer is on the bridge to assist in navigation, and there is a bow watchstander.
Inoperative Automatic Radar Plotting Aid (ARPA) and inoperative radar:
The COTP may allow a vessel to enter port during daylight hours only, provided there are at least three (3) miles of visibility. During your voyage a second licensed officer is required on the bridge to assist in navigation.
Inoperative Gyrocompass:
The COTP may allow a vessel to enter port during daylight hours only, provided there are at least three (3) miles of visibility. The pilot must agree that the vessel can be safely navigated with the magnetic compass and the existing deviation table. During your voyage a second licensed officer is required on the bridge to assist in navigation as well as a bow watchstander.
Inoperative Echo Depth Sounding Device:
The COTP may allow a vessel to enter port if clear visibility conditions exist. During your voyage a second licensed officer is required on the bridge to assist in navigation.
Inoperative Electronic Position Fixing Device:
The COTP may allow a vessel to enter port during daylight hours only, provided there are at least three (3) miles of visibility and the pilot determines that piloting conditions are safe.
VERIFICATION OF REPAIRS
LODs may be cleared by one of two methods:
1. On board verification of repairs by Coast Guard personnel, vessel’s flag administrator, or an authorized surveyor acting on behalf of the flag administration.
2. Independent third party verification by a repair technician. Written verification must contain the information listed below, but may be in any form. Examples include a copy of the servicing report, an invoice, or a statement on company letterhead.
Vessel Name
Equipment
Servicing Company
Technician’s Name
After verification that repairs have been made, the agent of the vessel will be notified that the vessel may depart. Since the vessel was not detained and because the LOD expired upon arrival at the destination, there is no formal release letter.
CFR 33 ; § 164.25 Tests before entering or getting underway.
(a) Except as provided in paragraphs (b) and (c) of this section no person may cause a vessel to enter into or get underway on the navigable waters of the United States unless no more than 12 hours before entering or getting underway, the following equipment has been tested:
(1) Primary and secondary steering gear. The test procedure includes a visual inspection of the steering gear and its connecting linkage, and, where applicable, the operation of the following:
(i) Each remote steering gear control system.
(ii) Each steering position located on the navigating bridge.
(iii) The main steering gear from the alternative power supply, if installed.
(iv) Each rudder angle indicator in relation to the actual position of the rudder.
(v) Each remote steering gear control system power failure alarm.
(vi) Each remote steering gear power unit failure alarm.
(vii) The full movement of the rudder to the required capabilities of the steering gear.
(2) All internal vessel control communications and vessel control alarms.
(3) Standby or emergency generator, for as long as necessary to show proper functioning, including steady state temperature and pressure readings.
(4) Storage batteries for emergency lighting and power systems in vessel control and propulsion machinery spaces.
(5) Main propulsion machinery, ahead and astern.
(b) Vessels navigating on the Great Lakes and their connecting and tributary waters, having once completed the test requirements of this subpart, are considered to remain in compliance until arriving at the next port of call on the Great Lakes.
(c) Vessels entering the Great Lakes from the St. Lawrence Seaway are considered to be in compliance with this sub-part if the required tests are conducted preparatory to or during the passage of the St. Lawrence Seaway or within one hour of passing Wolfe Island.
(d) No vessel may enter, or be operated on the navigable waters of the United States unless the emergency steering drill described below has been conducted within 48 hours prior to entry and logged in the vessel logbook, unless the drill is conducted and logged on a regular basis at least once every three months. This drill must include at a minimum the following:
(1) Operation of the main steering gear from within the steering gear compartment.
(2) Operation of the means of communications between the navigating bridge and the steering compartment.
(3) Operation of the alternative power supply for the steering gear if the vessel is so equipped.
(This article is for informational purposes only.)
Source: CFR 33 & The Marshall Island Maritime Administration
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