Rule to be realeased 8/15,

or, it just seemed so empty here…

Oh, never mind

It was supposed to be released every year for a while now. And I read only now are they requesting opinions on hours/rest/manning so that’s 5-15 years away from changing, if at all. What a joke! Lot of money to be made for “third party” compliance people. Maybe I’ll open an office in Oklahoma and never step on a tug again?

I cannot see the image. WTF are you talking about?

Screenshot of an email, first it showed that it uploaded, but it didn’t work, deleted it, tried it again, didn’t work, couldn’t delete the post in “edit”…

So here’s a copy and paste…

Good Morning All,

The latest Unified Agenda (UA), published on 11/21/14, now indicates publication of Sub “M” is planned for August 2015. Below is the link to the page in the UA.

http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201410&RIN=1625-AB06

Please call or email me if you have any questions.

Have a great day!

v/r

MST1 Jeff Merrell
U.S. Coast Guard
Sector San Francisco
Preventions Department
UTV Section
Tel: 510-437-5315

[QUOTE=DredgeBoyThrottleJocky;148701]Screenshot of an email, first it showed that it uploaded, but it didn’t work, deleted it, tried it again, didn’t work, couldn’t delete the post in “edit”…

So here’s a copy and paste…

Good Morning All,

The latest Unified Agenda (UA), published on 11/21/14, now indicates publication of Sub “M” is planned for August 2015. Below is the link to the page in the UA.

http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201410&RIN=1625-AB06

Please call or email me if you have any questions.

Have a great day!

v/r

MST1 Jeff Merrell
U.S. Coast Guard
Sector San Francisco
Preventions Department
UTV Section
Tel: 510-437-5315[/QUOTE]

The Spring 2013 agendaestimated that the STCW rule would publish April, 2013… it published on December 24, 2013. And that estimate was made only 4 months in before the estimated publication date.

[QUOTE=DredgeBoyThrottleJocky;148701]Screenshot of an email, first it showed that it uploaded, but it didn’t work, deleted it, tried it again, didn’t work, couldn’t delete the post in “edit”…

So here’s a copy and paste…

Good Morning All,

The latest Unified Agenda (UA), published on 11/21/14, now indicates publication of Sub “M” is planned for August 2015. Below is the link to the page in the UA.

http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201410&RIN=1625-AB06

[/QUOTE]

That’s only an estimate, the rule still has to be reviewed and approved by DHS. In the 2013 agenda the STCW rule was originally “scheduled” for April 2013, but didn’t publish until December 24, 2013.

So it looks like at least another couple of years before we have a COI that specifies how many crew, with what documents, are required on a tugboat. That’s a disappointment, but not a surprise.

I do not see how most tugs over 30 years old (and that’s the vast majority of US tugboats) can be upgraded in an economically feasible way to pass USCG inspection. It seems to me that inspection should be phased in over a period of several years as follows: (1) all new tugboats, (2) tugs towing oil, (3) tugs less than 10 years old, (4) outside boats 10 to 30 years old, (5) outside boats over 30 years old, (6) inside boats over 10 years old, and (7) inside boats over 30 years old. There are not enough USCG inspectors to inspect all the tugs within a couple of years anyway.

[QUOTE=tugsailor;148805]So it looks like at least another couple of years before we have a COI that specifies how many crew, with what documents, are required on a tugboat. That’s a disappointment, but not a surprise.

I do not see how most tugs over 30 years old (and that’s the vast majority of US tugboats) can be upgraded in an economically feasible way to pass USCG inspection. It seems to me that inspection should be phased in over a period of several years as follows: (1) all new tugboats, (2) tugs towing oil, (3) tugs less than 10 years old, (4) outside boats 10 to 30 years old, (5) outside boats over 30 years old, (6) inside boats over 10 years old, and (7) inside boats over 30 years old. There are not enough USCG inspectors to inspect all the tugs within a couple of years anyway.[/QUOTE]

Third party auditors and surveyors will be allowed to complete the audits required under Subchapter M. Many of the requirements are delayed for existing vessels for 4 or 5 years, if I remember correctly.

[QUOTE=Didley1jt;164434]Third party auditors and surveyors will be allowed to complete the audits required under Subchapter M. Many of the requirements are delayed for existing vessels for 4 or 5 years, if I remember correctly.[/QUOTE]

Yes. I have had a couple of contacts from third party surveyors, and I am trying to figure out if I want to get into this, at least on a part time basis.

I think the inspections/audits done by the chartering company (on oil boats) is as, if not more thorough than a USCG COI inspection…

Having been through COI inspections on both OSV’s and passenger boats, And recently a SIRE inspection. I would agree. The only difference being that we did drills for the USCG inspections.

[QUOTE=tugsailor;164439]Yes. I have had a couple of contacts from third party surveyors, and I am trying to figure out if I want to get into this, at least on a part time basis.[/QUOTE]

Depending on pay that sounds very tempting.