REQUIRED TESTS/DRILLS PRIOR TO ENTERING PORT

PRE-ARRIVAL TESTS 33 CFR 164.25(a):

The following tests are required to be conducted and entered into the vessel’s logbook,
no more than Twelve (12) hours prior to entering or getting underway in U.S. navigable
waters:

1. Primary/secondary steering gear:

a. Visual inspection of steering gear and its connecting linkage,

b. each remote steering gear control system,
c. each steering position located on the navigating bridge,
d. the main steering gear from the alternate power supply, if installed,
e. each rudder angle indicator in relation to the actual position of the rudder,
f. each remote steering gear control system power failure alarm, and
g. the full movement of the rudder to the required capabilities of the steering
gear.

2. Test all internal vessel control communications and vessel control alarms.

3. Test standby or emergency generator for as long as necessary to show proper

functions, including steady state temperature and pressure readings.

4. Test storage batteries for emergency lighting and power systems in vessel control,
and propulsion machinery space.

5. Test main propulsion machinery, ahead and astern.

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 DRILLS 33 CFR 164.25(d):

An emergency steering drill must be conducted within 48 hours prior to entry and
logged in the vessels 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. This drill
must include at a minimum, operation of the main steering gear from within the steering
gear compartment.

VITAL SYSTEM SURVEYS ON TANK SHIPS 33 CFR 157.35:

Prior to cargo operations vessel’s 5,000 gross tons and greater that carry petroleum oil in
bulk as cargo or cargo residue and that are not equipped with a double hull must conduct
the following surveys:
 a. Cargo systems
b. Mooring systems

The above surveys must be logged in the vessel’s deck log or other on board
documentation.

ENFORCEMENT ACTION:

Violators of the above regulations are liable for a civil penalty of up to $27,500 for each
violation.

REPORTING INOPERABLE NAVIGATION EQUIPMENT:

REFERENCE: Reporting Non-Operating Equipment 33 CFR 164.53

REGULATION: 33 CFR 164.53 (b) states that if the vessels radar, radio navigation
receivers, gyrocompass, echo depth sounding device, or primary steering gear stops
operating properly, the person directing the movement of the vessel must, as soon as
possible, report, or cause to be reported that it is not operating properly to the nearest
Captain of The Port.

POLICY: Upon written application (e.g. from the agent), the COTP may authorize a
deviation from any rule contained in 33 CFR Part 164. Written Letters of Deviation
(LOD) may be issued for the following systems or equipment:

 Radar primary or secondary (including ARPA);

 Radio navigation receivers;
 Gyrocompass;
 Echo depth sounding device; or
 Primary Steering Gear

If issued, COTP’s may also place certain restrictions or provisions on vessels when any
of the listed equipment is inoperative (i.e. the use of an additional tug, daylight operations
only, and/or good visibility, etc.).

LOD’s are not normally issued for other inoperative equipment required by 33 CFR Part
164 because the COTP places no special restrictions or provisions on the vessel. LOD’s
expire upon arrival at the vessel’s destination, except transit and departure LOD’s,
which expire when the vessel departs the COTP Zone.

An LOD is not a detention, however, the vessel must request a separate LOD to move
within or depart the port if the equipment is not repaired. Repairs must be completed
prior to departure. Departure LOD’s are only granted in extraordinary cases.
For transit or departure LOD’s where the vessel’s Next Port of Call is a U.S. port, a
separate LOD must be requested from that COTP(s) Zone. Each Captain of the Port will
determine the level of restrictions to be placed on a vessel on a case-by-case basis. If
equipment becomes inoperable during a voyage, the vessel may continue to the next port
of call subject to the discretion of the COTP.

A LOD should be requested utilizing a special form therefore the request to be sent via
the agent.

VERIFICATION OF REPAIRS:

LOD’s may be cleared by a vessels flag administration, an authorized surveyor acting on

behalf of the flag administration, or an independent third party FCC licensed repair
technician.

Written verification of the repairs must contain a summary of the problem, corrective
measures taken to make equipment operable, as well as the vessel name, equipment
Servicing Company, technician’s Name, U. S. Federal Communications Commission
(FCC) License Number. Examples of written verification include a copy of the servicing
report, an invoice, or a statement on company letterhead.

After verification that repairs have been made, the agent of the vessel, as well as the
Coast Guard’s Vessel Traffic Center (if appropriate) will be notified that the vessel is
cleared to depart.

Since the vessel was not detained and because the LOD previously expired upon arrival,
usually, no formal release letter will be issued. .