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WORKBOAT ANNUAL Why Should The Words "Substantial Alteration" Or "Major Modification" Scare Vessel Owners by Charley Havnen, contributing writer Each U.S. Coast Guard (USCG) ruling that a vessel has undergone a substantial alteration or major conversion is a separate determi- nation that can trigger a cascade of requirements leading to the vessel being re-admeasured and inspect- ed by the USCG as if it were newly built. For any existing vessel, either of these rulings can be cata- strophic. A ruling that a vessel has under- gone a substantial alteration for vessels involved in international voyages could mean the applicabil- ity of Safety of Life At Sea (SOLAS) Convention where not previously required, or the use of a new date of construction by which various requirements under SOLAS are determined to apply. For more than a year, the USCG has been indicating that any change in a vessel's gross tonnage of more than one percent will con- stitute a substantial alteration. The USCG has recently modified this policy, increasing it to a five percent change in the ITC gross or net tons. The change was published as Change 2 to the USCG's Navigation and Vessel Inspection Circular (NVIC) 11-93. It should be noted that the new five percent figure applies only to vessels constructed after July 18, 1982. Those vessels whose con- struction was started prior to the 1982 date will continue to have the one percent criteria applied to determine if a substantial alter- ation has occurred. A vessel ruled by the USCG to have undergone a major conver- sion would require a new set of drawings reflecting the vessel's current as built condition and resubmitting them to the USCG for approval under the new ton- nage as if it were a new vessel. The keel laying date is used to determine the application of domestic regulations, as well as international rules. If the vessel in question is an Offshore Supply Vessel (OSV), it would mean applicability of the regulations now applicable to new OSVs, 46 CFR Subchapter L. For an older passenger vessel under 100 gross tons, it could mean being required to rebuild the vessel to today's lat- est regulations. The origin of major conversion is a 1988 amendment to Title 46 of the U.S. Code. 46 USC 2101(14a) defines a major conversion as being a vessel modification that does one of the following: • Changes the dimensions or car- rying capacity; •Changes the type; (Continued on page 31) CYGNUS FAMILY OF MARINE INSPECTION EQUIPMENT • MULTIPLE ECHO METAL THICKNESS GAUGES Coatings DO NOT Hove to be Removed • QUANIX COATING THICKNESS GAUGES Easy to Use - Very Competitive Prices • MECHANICAL PIT GAUGES Inch and Metric Versions CYGNUS INSTRUMENTS P.O. Box 6417 Annapolis, MD 21401 888-CYGNUS5 (toll free) 410-268-2013 (FAX) CYGNUS INSTRUMENTS INC. WORKBOAT BOOTH # 1861 Circle 252 on Reader Service Card mX Marine Deck Hardware and Equipment • ANCHORS: • 50 to 60,000 Lbs. - New and Used Stockless - Danforth - L.W.T. - Halls - Snug Slowing • CHAIN • to 5'/s" - New and Used Stud Link - Cast Steel - Grades 2 and 3 - Oil Rig Quality for Moorings, Towing, Barge Handling, Ship's Replacement • WINCHES - WINDLASSES - CAPSTANS • Vertical or Horizontal Hand, Electric, Diesel, Hydraulic or Repowered to your specs • HATCHES - WATERTIGHT DOORS MANHOLE COVERS - SCUTLES - PORTHOLES • All Sizes - New or Reconditioned • PANAMA CHOCKS - DOUBLE BITTS SINGLE BITTS - CAST STEEL CLEATS AND KEVELS • ' GIGANTIC AI1 Sizes Available, New & Used INVENTORY • FENDERS PNEUMATIC • NEVV & For Rent or Sale USED/ All Sizes, New & Used SERVING THE MARINE 6 OIL INDUSTRIES FOR OVER 35 YEARS WE ARE DIRECT FACTORY DISTRIBUTORS 6 IMPORTERS rATERMAN SUPPLY CO., IMC. P.O. BOX 596 WILMINGTON. CA 90748 PH: (310) 522-9698 FAX: (310) 522-1043 Circle 371 on Reader Service Card 26 Kort Nozzles All Sizes We Build To Customer Drawing And Specifications Certification Upon Request "Made In The USA" For A Brochure Write Or Call: Custom Nozzle Fabrication/CNF P.O. Box 547 Pascagoula, MS 39568 (601) 762-4612 Fax: (601) 769-0558 See us at the Workboat Show, Booth #1760 Circle 250 on Reader Service Card
