I am now working on a boat operating under Safety Management System and we have a “rest period log.”
Operating policy is clear that the rest log be maintained only when operating beyond the boundary line as defined in 46CFR part7. But, it is unclear about which crew members need to keep an individual rest log. Each Officer in Charge of a Navigational Watch and each Officer in Charge of an Engineering Watch is included, but from what I see unlicensed crew members are NOT included unless they have RFPNW or RFPEW and need not be included at all in the rest period log.
Is this right?
Thanks,
Harry
P.S. Who is the governing authority for Safety Management System?
[QUOTE=highseasharry;70149]P.S. Who is the governing authority for Safety Management System?[/QUOTE]
Governing authority is the USCG for all US flagged ships under 33CFRpart96 but functional authority to manage the approval and audits of Safety Management Systems is delegated to the recognized class societies ABS, LR and DNV.
Concerning the question of which crew must submit work/rest logs, my understanding is that any STCW certified members of a vessel’s manning must be part of that record (at least that is how it has been on all the vessels I’ve run).
This one small piece of all of the paperwork foisted on the small crews of the ATBs was critical in my decision to draw “early normal pension”. When first implemented, I pointed out that it was impossible to operate under the guidelines, especially with multiple loads and discharges in a port. And even worse was finishing up a yard period and getting underway. Updated rules and instructions later had so many caviats like radio watch, paper work and meal time wouldn’t constitute hours worked. I’m surprised there was no $hithouse deduction.
I’ve heard manning has increased. I hope the work rules have gotten better.
[I]“I’ve heard manning has increased. I hope the work rules have gotten better.”[/I]
Where’d you hear that? Maybe a few outfits have added a man or two, but it’s unrealistic to expect to see a mandated manning increase anytime soon from the USCG. They don’t appear to have any interest in dealing with the elephant in the room. The only mandated increase you’ll see is when a boat goes foreign and needs three watches for the duration of the trip. Domestically, the minimum number of bodies and two watches is the rule for many. If anyone really looked at the crew rest records, I’d be willing to bet they’d find every vessel in violation.
[QUOTE=injunear;70200]This one small piece of all of the paperwork foisted on the small crews of the ATBs was critical in my decision to draw “early normal pension”. When first implemented, I pointed out that it was impossible to operate under the guidelines, especially with multiple loads and discharges in a port. And even worse was finishing up a yard period and getting underway. Updated rules and instructions later had so many caviats like radio watch, paper work and meal time wouldn’t constitute hours worked. I’m surprised there was no $hithouse deduction.
I’ve heard manning has increased. I hope the work rules have gotten better.[/QUOTE]
Before restrictions on work hours captains and chief’s jobs were easier, just have the chief mate / 1 A/E do everything. Typically they are competent, hard working and ambitious and will get it done. Now we have to get the junior officers up to speed and we also have to deal with the higher risk levels associated with having less experienced officers working unsupervised more often.
K.C.