Implications of Subchapter M for Engineers


#1

As I write this, most companies who own tugs are getting manning requirements from the CG. they are voluntarily getting audited and a COI with manning requirements is being created by the CG. This is really only affecting the engine department. When the companies receive their new COI, it usually states that the tugboat (which used to only have a deckineer) now has to carry a chief limited and a DDE 4000.
The company immediately sends a rep to the CG to argue that, “hey we have always run deckhands before, or a DDE 1000” and the Coast Guard usually sees their point and adjusts the COI so that now the vessel only has to carry a DDE 4000, or DDE 1000.
What this means is that for guys like myself, and many more of you all, who have worked through the ranks, tested, studied, etc…, that your license is becoming obsolete. It took me ten years to get the licensing that I have, and I am finding that there are no jobs out there. Sure I could sail on an ATB or tugboat, but these are jobs that only require a DDE!! Even on a massive boat, with 12000 hp! The Chief Limited license is becoming completely obsolete. There is no one to argue for the mariner, so the companies are winning.
Oh and if you want to sail unlimited, just make sure you get the divorce and stuff out of the way first. These unlimited and union jobs often require sailing for four months! While the deck department stacks on more and more people, the engine department gets people taken away.

I know that all you Captains will be making plenty of rude comments on this post, but the lack of skill and experience in the engine room will make your lives difficult also.
All of us with intermediate licenses,Chief Limited etc., need to write the Coast Guard and ask them to stick to their guns on the licensing requirements for the engineers, before we are working for less than deckhands.


#2

At this moment I have not seen a COI for a UTV. The only thing that I know being asked and highly recommended for UTV’s is a Safe Manning Document or Safe Manning Letter, but it is not an obligation to have one. Unless it is required by your own TSMS or if its classed (also it could be required by a specific contract) . Depending of the tonnage of the tug. Also, the Coast Guard for UTV’s only do examinations.


#3

I don’t think a pre-sub chapter m safe manning doc would be influenced by yet to be published regulations, but that’s just my opinion. And manning for a safe manning document is somewhat standardized by existing regulations IIRC. If so I’d love to see one and some background.

Most of these vessels legally sail with no license chief as it is, so requiring a DDE1000 is an upgrade in my book. Sounds like you’re new to tugs and uneducated on the topic?


#4

[QUOTE=0rion;184908]At this moment I have not seen a COI for a UTV. [/QUOTE]

COI for UTV?


#5

Also a SMD or SML is practical on a international or foreign trip, it makes it easier to deal with Port State. Use the International Addendum for UTV’s.

On domestic waters or coastwise I dont have a clue of why a UTV company would ask for a SMD or SML.


#6

Exactly, follow the conversation. I just didnt want to sound rude in my initial statement, obviously we wouldnt be talking about Subchaptwr M to this date if aUTV could get a COI.


#7

[QUOTE=0rion;184913]Exactly, follow the conversation. I just didnt want to sound rude in my initial statement, obviously we wouldnt be talking about Subchaptwr M to this date if aUTV could get a COI.[/QUOTE]

UTV’s are getting a COI per this new subchapter M ruling. Therein lies the problem, they are undermanning these vessels in my opinion. And it’s going to affect all licensed engineers negatively.

      • Updated - - -

It’s all taking effect Dec 2016. With these manning requirements, it leaves a gap. A lot of companies used to require chief limited on their higher horsepower tugs, but this ruling is allowing them to run DDE’s.


#8

Yeasty, the initial comments that started this stated that a certain company got a COI and it required a specific manning for engineers.

To this date, even with the stage of Subchapter M a UTV cannot have a COI.

In the future, or near future UTV will have a COI and then they wont be UTV anymore.

But any company (UTV)that is saying that they have a specific manning based on a COI is lying.


#9

They also can run with mate/Master of towing licenses, but require 1,600 licenses, AB’s, None of which is needed in many cases.


#10

[QUOTE=Yeasty McFlaps;185018]UTV’s are getting a COI per this new subchapter M ruling. Therein lies the problem, they are undermanning these vessels in my opinion. And it’s going to affect all licensed engineers negatively.

      • Updated - - -

It’s all taking effect Dec 2016. With these manning requirements, it leaves a gap. A lot of companies used to require chief limited on their higher horsepower tugs, but this ruling is allowing them to run DDE’s.[/QUOTE]

I might be missing something but I do not see a problem. What you are stating is that if and when they come out with a COI that may or may not include minimum manning levels (which I hope they do to stop companies from running with a 2-4 man crew) that if they only require a very small Engineers License, DDE of some sort, and how it will hurt those that hold higher Licenses. So, if I have this right you are worried about a company passing up on a higher level license when they can satisfy a COI with a DDE.

Here is my question to you. What is the difference from what they now have as there is NO requirement to even have a Licensed Engineer onboard???

I do not see a company that as of now requires at the Least a Limited Oceans Chiefs License would lower their standards and go with a DDE. Let’s face it if they (Company Policy) required a CE License when there are NO Requirements to even have a Licensed Engineer WTF would they Lower their minimum when they far exceed the present minimum of NO Licensed Engineer???


#11

Exactly.

The future COI for what today is a UTV will have a minimum manning level. But that can be changed by company policy or even contract based for a higher standard, and here is where the creative firing comes into play…


#12

#13

A tugboat doesnt need a big licence. It’s a place for dde’s to sharpen their skills. And a dde unlimited licence is nothing to scoff at. The test is just as difficult as a third assistant. Horsepower doesnt mean anything. It’s the amount of systems and crew management that would necessitate a chief. No company is going to pay a ce big tonnage rates to basically sit in an engine room in charge of a 20x30 space.