Are Articles required for Tugs/ATBs?

  • Vessel Name: KIM M. BOUCHARD
  • USCG Doc. No.: 1257372
  • Vessel Service: TOWING VESSEL
  • IMO Number: 9753179
  • Trade Indicator: Coastwise Unrestricted, Registry
  • Call Sign: WDH8113
  • Gross Tonnage: 190 *

This vessel would be subchapter M, towing vessel under 300 GRT, correct?

136.105 Applicability.

(a) This subchapter is applicable to all U.S.-flag towing vessels as defined in §136.110 engaged in pushing, pulling, or hauling alongside, except—

(1) A vessel less than 26 feet (7.92 meters) in length measured from end to end over the deck (excluding the sheer), unless that vessel is pushing, pulling, or hauling a barge that is carrying oil or hazardous material in bulk;

(2) A vessel engaged in one or more of the following:

(i) Assistance towing as defined in §136.110;

(ii) Towing recreational vessels for salvage; or

(iii) Transporting or assisting the navigation of recreational vessels within and between marinas and marina facilities, within a limited geographic area, as determined by the local Captain of the Port (COTP);

(3) A workboat operating exclusively within a worksite and performing intermittent towing within the worksite;

(4) A seagoing towing vessel of 300 gross tons or more subject to the provisions of subchapter I of this chapter;

That’s the way I do it as well.

If I’m on a regular run it will be all in good order. The problem I run into when the ship’s schedule jumps from one run to another. For example finish a round-the-world run and then instead of another got to run up and down the East Coast of S. America. (ECSA) or the WCSA. Or they will throw in new ports to the regular runs, like Mersin Turkey.

It’s very time consuming having to figure out port arrival paperwork when you don’t have the forms from the last trip. I got a couple fines from “The Doctor” in Santos. Did you know that if you call a port in Venezuela that the regular eNOAD is not sufficient? Neither did my relief. Got held by the CG for 24 hrs outside Beaumont.

I see it like triage. Sometimes can’t get everything done so got to start with the “show-stoppers” and work down from there. Not to mention keeping an eye on navigation and the weather.

In my experience having signatures missing will not prevent the ship from breaking articles at the end of a voyage. Otherwise I’d still be stuck. Or not, might have to use MS Paint and get the missing signatures that way. I’ve done that with the customs crew declaration a couple times. Looked a little goofy but it flew.

And yes, I realize it’s not kosher. My test is “what do I have to do to get this ship out of port and on the way to the next?”

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Don’t know for sure. It’s not an issue of inspected vs uninspected. NVIC 1-86 mentions both.

It certainly appears to be subject to Subchapter M

But, so what?

Subchapter M doesn’t exempt towing vessels from the need to sign articles or issue discharges.

Seems to be this, has been a real conundrum to be truthful

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