Notice of Proposed Rulemaking: Inspection of Towing Vessels

The NPRM was released today. Click here to view it.

Of course the first section I wanted to read was the work/rest proposal. After all this time the issues of a realistic program for dealing with uninterrupted sleep escape reality. There isn’t any way I can see that 7-8 hours of quality sleep (their term) can be had on a working tug. A 24 hour operation means noise and disrupted sleep for the duration of a 2-3 week hitch.
How does the proposal begin to offer a real solution to the bump and grind of a working tug boat? It won’t address the travel to the vessel before taking a watch which can mean a 12-14 or more hour ordeal just getting to the boat. Then someone has to take a watch and get underway after that. No rest, just go.
In fact, even if we went to a three watch system for everyone we still wouldn’t see perfect “uninterrupted” sleep when the boat is moving.
We’ve been sleep deprived forever, it comes with the job.
The only real solution might be increasing the crew compliment to allow some possibility of a proper rest cycle. And to that I ask, where is the 3rd watch going to come from?
Is this a step in the right direction for maintenance, machinery and safety equipment, yes. Is it going to solve the crew rest/fatigue issue, no. Cite all the studies you want, unless it’s mandated by law this one issue won’t go away.

“As noted above in Section IV.J. “Manning,” we are not proposing to change any of the current manning levels required for towing vessels. However, portions of the TSMS covering operations should address many of the concerns raised by these commenters.”

Until it is mandated, [B]NOTHING[/B] is going to improve. In fact, with the economy, I would suspect it is only going to get worse. It’s going to take a huge accident that can be, at least in part, directly attributable to insufficient manning before this changes. I’m not talking about someone dying, they don’t care about that, I’m talking about something like a significant oil spill in NY Harbor.

When the Miss Niz caught fire in the Kills they had a Captain and a Deckineer onboard. One tug, one barge, two men. The prudent decision for the Captain would have been to refuse to leave the dock without at LEAST one man dedicated as an engineer and a deckhand. All that would have done is cost him his job. You could hear the panic in the Captain’s voice on the radio because he couldn’t leave the wheelhouse to get a status update or even know if the other man onboard was okay.

Sleep deprivation? They’ll hang the mariner, they’re never going to penalize the company for it.

I never expected anything really substantive from the USCG regarding manning. They just don’t have the will or horsepower to push it through. Like you said, it’ll take a high profile incident in the heart of NY Harbor, San Francisco or New Orleans again to get any attention. And then, of course they will hang the crew, there isn’t any reason to go after the company since they didn’t break any law.
Looks like Kirby (since taking over KSea’s fleet) is trying to reduce crew sizes on their ATB’s to 5 men instead of 7 or 8. If they succeed at that, the aforementioned incident will only be a matter of time. And it will happen.

Here’s the press release from USCG

WASHINGTON — The U.S. Coast Guard announced Thursday publication in the [I]Federal Register[/I] of a notice of proposed rulemaking (NPRM) designed to improve safety on towing vessels.
The NPRM provides a layered approach to towing vessel safety that includes the option of an audited safety management system or an annual Coast Guard inspection regime. The NPRM also includes procedures for obtaining Certificates of Inspection issued by the Coast Guard, and for Coast Guard oversight of any audit and survey processes involving third party organizations.

Additionally, it would establish safety regulations governing the inspection, standards, and safety management systems for towing vessels. These include requirements for lifesaving and fire protection, electrical and mechanical items, and operational requirements such as crewmember training and drills, navigation and towing safety, and recordkeeping provisions.

The Coast Guard has worked closely with the Towing Safety Advisory Committee in developing this proposed rulemaking and now encourages public comment on the proposal. Interested parties can review the proposal and submit comments and related materials at, docket number USCG-2006-24412. All comments are posted without change. The comment period ends on Dec. 9, 2011.

“This NPRM, which proposes an inspection regime for a previously uninspected class of vessels, is the result of the Coast Guard working closely with industry to improve vessel safety to prevent accidents and protect vessels, crews, cargoes, our shared waterways, and our environment while being mindful of the burden created by regulations,” said Coast Guard Deputy Commandant for Operations Vice Adm. Brian M. Salerno.

While at this time, there is no specific proposal regarding requirements for hours of service and crew endurance management for mariners aboard towing vessels, comments on this important topic are encouraged and will be considered when the Coast Guard decides whether to propose such requirements in the future.

The Coast Guard’s current Towing Vessel Bridging Program efforts, which address verifying compliance with existing regulations, will not be impacted by these proposed regulations.

The NPRM can be viewed here.

Remember, if crew size is increased to cover a work hour/ manning law, your pay WILL decrease.

[QUOTE=waterman74;53963]Remember, if crew size is increased to cover a work hour/ manning law, your pay WILL decrease.[/QUOTE]
What a crock. The cost gets passed along like any other business expense. The increase in manning will be industry wide. The dearth of qualified people will drive the mariner’s value UP, not down. More people will need school and training so the transition would take years to implement AFTER its enacted… If there is a regulated manning requirement, industry will be competing for the best mariners out there to move their vessels.

[QUOTE=waterman74;53963]Remember, if crew size is increased to cover a work hour/ manning law, your pay WILL decrease.[/QUOTE]

Only for those stupid enough to accept a decrease in pay. While there is a glut of licensed, qualified personnel at the moment. A change in law and regulation, particularly in response to an incident, would eliminate that glut, almost overnight. The increased cost of insurance for not having adequately licensed personnel, as defined by the insurance companies, wouldn’t even make it close to a wash. The companies would absorb, and pass on the cost, as Capt Brucato indicated.

That doesn’t even address the subject of Union’s. While cappy may have misunderstood me, I am under no delusion that union’s have [B][U]no[/U][/B] affect on the wages of non-union personnel. Bottom line is, if there is a HUGE disparity in wages from one region, or one employer, to another, people WILL move.