Well, now I know why I’ve seen pics of tiny tugs pushing giant gravel barges around NY harbor.
From Sub M
§ 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;
To be clear, that definition predates Subchapter M. (Probably since the invention of the Master/Mate of Towing licenses in the late '90s / early '00s but I’m not positive.)
Is that an old reference and incorrect? If so, I’ll take it down. I hate finding stale rules/regs on a website. I thought I grabbed it off eCFR, but maybe not.
Towing vessel means a commercial vessel engaged in or intending to engage in the service of pulling, pushing, or hauling alongside, or any combination of pulling, pushing, or hauling alongside.
But perhaps tugsailor has a different USCG definition that excludes anything under 26 feet?
I think that definition of “towing vessel” has been around since the Operator of Uninspected Towing Vessels licenses were first created in the 1970s?
I recall a barge company in 1980s getting its hand slapped by the USCG for using unlicensed shoreside guys to run boats that were over 26 feet to move barges in the harbors. As I recall, those boats were about 40 feet. Those boats were replaced by more powerful and actually bigger boats that were just under 26 feet.
Ok. I asserted earlier that tugs under 26 feet don’t actually fall within Subchapter M. But it is just not true that USCG has a definition for “towing vessels” that excludes everything not covered by Subchapter M. 46 CFR 27 is entirely dedicated to Towing Vessels and has the exact same definition:
I only joined this thread to respond to the question:
I interpreted this question as seeking a way around operating a tug if you don’t hold a master of towing or hold a TOAR. So I think my response was accurate as far as I know. If you are endorsed for assistance towing, you still can’t operate a Subchapter M vessel which means over 26 feet. If you are running something under 26 feet, you still need a proper license in order to conduct “assistance towing.” You don’t need any license to operate a 26 foot tug pushing this and that around a site
I’ve never been in the assistance towing business or had an assistance towing endorsement, so I wouldn’t know about that.
I knew a guy with Master 1600, but without Master of Towing , that worked for SeaTow on a 45’ boat doing assistance towing. I assumed that was legal, he was doing it, SeaTow ought to know what is required, but I really don’t know.
I was once contacted by a guy that had an antique 65 foot wooden tug, he was running it as a 6 passenger uninspected passenger vessel. The USCG came a long and told him that since it was registered as a tug, he had to have a Master of Towing to operate it. I suggested that he reregister the boat as a yacht, not a tug. I don’t know what he did.
I’m guessing here, but a small inspected passenger passenger vessel (Sub T) can be sold, COI surrendered, and be re-registered as an unispected vessel. Similarly, I assume a towing vessel (Sub M), can be sold, COI surrendered, and re-registered as an uninspected vessel and engage in commercial assistance towing.
Like a sub T boat, I assume the COI for a sub M boat (Never seen one) specifies that Master and Mate hold the proper license (MOT or Master/Mate >200 with TOAR???). Once the COI is surrendered, it could be pressed into service in the “Assistance Towing” industry by having a plain old, lowly Master (insert appropriate tonnage) with “Assistance Towing Endoresement” (Well, strike out “sold”, and just go with “surrender COI”)
Man, if that is all accurate, I’m buying myself a beer.
I think that could work. Or since you are buying your own tug, it shouldn’t be much of a problem to get someone to write your TOAR and then you can tow and do assistance towing.
Back when I worked with Towboat US, a assistance towing endorsement was good for vessel under 26 foot, above that required Master of Towing. However I saw Towboat US vessels slightly larger (27)
Sea Tow and the others were “caught” when the USCG examined this on the 2000s. There was a glut of yellow boats over 26 feet suddenly on the market. Nowadays they are supposed to be less than 26ft.
There was even a certain guy in NY that literally chopped and bobbed his 30 ft boats to come in under 26feet. He hung the rudders on pillow blocks over the stern. Don’t ever work for him, he had his license revoked by USCG, busted by NYC for no insurance and has killed 5 guys in his employ.
I digress. We call those push boats under 26 feet rule beaters.
If the boat is a tug or towboat, even if not inspected by Sub M. If the document says towing vessel you must have a master of towing on there, even light boat, according to the USCG.
I literally had this discussion with a couple of deckhands. Deckhand A tells Deckhand B that “he really should get 100 ton master on his MMC” so he can moonlight on dinner boats. Deckhand B just graduated Kings Point.
I waited until A left and schooled B. B went on to work for Maersk, I doubt he has the need or desire to moonlight, but should he, he should not work for anyone that cannot look up a CFR.
I don’t think the USCG would even do it if requested.
