Subchapter M UTV's

After the annual towing form at Suny maritime back in October, there was a lot discussed on Sub-chapter M and how its going to change the towing industry. Just want to see what others in the industry think. Some ideas are utilities towing license, inspected towing vessels, excess cost, and how it will hurt the small tug companies. I would like to get this discussion going since sub-chapter M is coming.

From what I have recently heard, ‘Uncle Sams Confused Group’ is backing off the implementation of towing vessel regulations. It is AMAZING how a little ‘grease’ in the right palm can make the industry regulation be swept under the rug. More reason the USCG should NOT be in charge of a civilian industry!

The answer to the question is: We ALL need to write, visit and call our US Representatives, Senators, and anyone else who is in a position to actually MAKE the laws so we can influence the outcome to our benefit. Right now the only one’s who are lobbying are Industry via AWO, Intertanko, and the like. The Unions are not really going on the offensive. The only organizations I have seen remotely involved (in the planning stages) are Gulf Coast Mariners, and MTVA.

It is interesting to see how the industry has been whipsawed back and forth over the last 20 years, from needing less oversight, to needing more oversight. First a towboat allision with a railroad bridge, and a towing vessel tripping lead to more stringent licensing and experience qualifications. Then the industry can’t find help (who reading this is out of work?) and successfully lobbies to have the more stringent regulations relaxed (again.) Then after another incident, they will be made more stringent.

I firmly believe that the 20+ year USCG ‘veterans’ should be prevented from entering into the same industry they spend the first 20 years of their careers regulating, then spend another 10 or 15 years working to ‘get around’ the same regs they implemented.

The analogy to this would be:
an individual who spends 20 years in an industry THEN goes into the regulatory end is OK. This person KNOWs the industry they are regulating.

But a government employee retiring and entering the same industry they regulated in the past is neither professional nor efficient.

Since when is government efficient, rational, professional and responsive. Private industry obviously needs oversight and regulations to follow. But a quasi-military USCG enforcement and interpretation of private industry is wrong.

Boy am I pissed off (as usual) at the USCG and politics. Sorry for the rant!

When they start inspecting the tugs look for a lot of small companies (and at least 1 big one) to go out of business and/or sell half their fleet to fix up the other half. Im all for it though, it would make our lives a little bit safer out there. The bad part will be the guys who loose their jobs.

[QUOTE=cappy208;46660]From what I have recently heard, ‘Uncle Sams Confused Group’ is backing off the implementation of towing vessel regulations. It is AMAZING how a little ‘grease’ in the right palm can make the industry regulation be swept under the rug. More reason the USCG should NOT be in charge of a civilian industry!

The answer to the question is: We ALL need to write, visit and call our US Representatives, Senators, and anyone else who is in a position to actually MAKE the laws so we can influence the outcome to our benefit. Right now the only one’s who are lobbying are Industry via AWO, Intertanko, and the like. The Unions are not really going on the offensive. The only organizations I have seen remotely involved (in the planning stages) are Gulf Coast Mariners, and MTVA.

It is interesting to see how the industry has been whipsawed back and forth over the last 20 years, from needing less oversight, to needing more oversight. First a towboat allision with a railroad bridge, and a towing vessel tripping lead to more stringent licensing and experience qualifications. Then the industry can’t find help (who reading this is out of work?) and successfully lobbies to have the more stringent regulations relaxed (again.) Then after another incident, they will be made more stringent.

I firmly believe that the 20+ year USCG ‘veterans’ should be prevented from entering into the same industry they spend the first 20 years of their careers regulating, then spend another 10 or 15 years working to ‘get around’ the same regs they implemented.

The analogy to this would be:
an individual who spends 20 years in an industry THEN goes into the regulatory end is OK. This person KNOWs the industry they are regulating.

But a government employee retiring and entering the same industry they regulated in the past is neither professional nor efficient.

Since when is government efficient, rational, professional and responsive. Private industry obviously needs oversight and regulations to follow. But a quasi-military USCG enforcement and interpretation of private industry is wrong.

Boy am I pissed off (as usual) at the USCG and politics. Sorry for the rant![/QUOTE]

Don’t be sorry for the rant, we need people to rant, its the only way to fix problematic government regulations.

I definitely agree with you on this, in the history of the U.S. there has never been a industry to prosper from government regulation. in this case uncle Sam’s confused group are definitely making matters worst. a quasi military scheme such as USCG should not be involved in regulating a private industry. We need government to back away and allow the free markets in this case the towing industry to weed out the problems. i see in the future a lot of small companies going under (not creating jobs), because they can afford to fix/fight the regulations put on them. What i’m curious about is small marine construction type companies who have 1-5 old tugs, how are they suppose to know the regulations being passed or even understand it(i know i know CFR’s but not everyone understands them, especially the USCG-you would know this if you have every done a COI), i am very lucky to have gone to the towing form at Maritime and see whats coming. I believe this regulation on Sub-chapter M is destroying small tugboat companies, and making everyone work for big corporations.

WE NEED JOBS, NOT REGULATIONS!!!

Actually we DON’T need people to rant. We need sailors, Mates, Captains to send clear, simple concise letters to our politicians to affect the outcome of this issue.

We also need to realize that the people who make our laws are NOT sailors. Do any of you know a ‘street’ guy who knows about our life? Politicians are ‘street people.’ The only way politicians know about the ‘truth’ is by letters, calls, and (I hate to say it) donations from US. Only Merchant Mariners know about our life.

Don’t for a second think your company has ‘your back’ on this. If they could they would hire a Filipino to take your job. (That is one law that hasn’t been gutted yet)

If the office could replace us with a machine they would. Only by becoming involved in the legislative process will we be safe.

Why not call your Congressman or Senator on Monday? What could it hurt? Maybe it will help!

i was to absolute that regulation is bad, the Jones act which secures our U.S. jobs from foreigners is great, however tariffs on imports and deregulation on imports has cause excess spending in the country(but that is another forum). i disagree on Filipino, i believe company would hire Mexicans due large surplus of illegals in this country. im going to call my congressman, however being from a pro regulation state it will be like talking to a robot as mentioned above. Maybe we need a different organized group that represents mariners, not corporations or unions-good idea cappy208.

[QUOTE=KennyW1983;46665]When they start inspecting the tugs look for a lot of small companies (and at least 1 big one) to go out of business and/or sell half their fleet to fix up the other half. Im all for it though, it would make our lives a little bit safer out there. The bad part will be the guys who loose their jobs.[/QUOTE]

I think that same one you talk of will have problems & they will end selling out or going broke.

[QUOTE=cappy208;46660]
The analogy to this would be:
an individual who spends 20 years in an industry THEN goes into the regulatory end is OK. This person KNOWs the industry they are regulating.

But a government employee retiring and entering the same industry they regulated in the past is neither professional nor efficient.
[/QUOTE]

Cappy,

  1. They don’t "know the industry " as you so eloquently put it. That is what you think. The regulators u r talking about don’t know anymore than anyone else. They can read, they can interpret just like you read and interpret things. The difference between them and you is you are out there every day doing the job so you know what is needed. I was in and I don’t think they are very good. I saw an inspection at another vessel/company recently where the regulator could not tell if a fathometer or an HF radio were working correctly and passed them instead of actually testing them (i.e. comparing the display to charted depth or making a radio call). This is who you want coming onboard to make sure your vessel is safe??? This is where we ended up with the inspectors at MMS.

  2. I am p.o. at the USCG a lot of the time just like you. I am still not seeing who you want to enforce the rules and regulations. I do not trust private industry policing themselves. Perhaps an international organization of experts. No, that would be the IMO and they are worse than the USCG. If there was a reasonable alternative, I would support. Then I could justify my retirement and weaseling my way around government regulations.

  3. If you want to see/make a difference, do not bother writing or calling your congressman, sign up and serve on some of the USCG Safety Advisory Committees. If you look at the membership lists now, they are full of industry higher ups (Executive VP of this, Executive Legal Counsel of that, etc…) This is where the USCG is getting most of their input on regulations. The other input is marine casualties where mariners are dieing or oil is spilled. It is those committees with the industry people on them and money to the right congressman that are watering down regulations and causing the about faces on certain issues.

Sometimes the evil you know is better than the evil you do not…

Boats:
It is funny how you and I have a hard time communicating. I know my writing style rambles. Sorry.

I actually was referring to the same people you were in your example 1. I was mentioning people who have done this for 20 years meaning the running of the boats. Then going into the regulatory end

The idea of joining a SAC was investigated by myself. I can’t see how I could be ‘lured’ for GS 12 to 14 pay. IIRC that was around 48 to 52K a year! How is the government thinking they would attract qualified, competent help for that kind of coin? I don’t know of a single Captain who is worth their salt who would go to work for that kind of money. I have to live, as well as feel good about what I do for a living. The only Civilian Marine Investigator opening last year was in Paducah. Sorry, but I am not a brown water sailor. And the thought of making the previously mentioned pay almost anywhere I want to live would be almost starvation wages.

Your observation of the committees is spot on. I can’t join for no pay. I don’t have a 20 year pension to help make up the difference. I need to pay the bills. The mentioned corporate members are paid their full salaries by their companies while they are attending and making policy. Sounds sort of like corporate sponsored governmental regulation!

[QUOTE=cappy208;46853]Boats:
It is funny how you and I have a hard time communicating. [/QUOTE]

Cappy,

I don’t think it is you. I probably can’t read very well and when you become old, cranky and cynical…

You may not be a brown water sailor but I bet you can tell if a fathometer is working or not.

I am applying to NAVSAC and hope to be accepted. I hope I can make a difference for the guys and gals that are out there doing the job.

[QUOTE=EHmarine;46670] in the history of the U.S. there has never been a industry to prosper from government regulation.[/QUOTE]

As much as I share most folk’s opinion on how the maritime industry suffers under the less than enlightened oversight of the current version of the USCG, the statement above is not entirely correct.

The FAA and its predecessor, the CAA was established in order to “… regulate air commerce to promote its safety and development” and to “promote, encourage, and develop civil aviation.”

There is no doubt about the success of those goals. Even today the policies which were put in place to make sure American airspace is a safe as a human can make it, and airline passengers and freight are as safe as technology can make it, have been very successful. It is because of those government regulations that there is no such thing as a “flag of convenience” airline. Air Zamboogiland will never fly a tramp airliner resurrected from some third world boneyard on a flight from Seattle to Orlando and undercut American Airlines to fill the airplane with unsuspecting tourists. If we applied the same financial, maintenance, training, and licensing standards to foreign ships that we do airliners we would be hard pressed to train enough mariners to man the huge fleet of American ships needed to handle our imports.

Don’t lump all government regulations and regulators in with the mismanagement revolving door policies that have corrupted maritime oversight in this country.

[QUOTE=Steamer;46862] the statement above is not entirely correct.

The FAA and its predecessor, the CAA was established in order to "…[/QUOTE]

Exactly my feelings too. However the main point lost is the FAA is set up of industry professionals who set up, oversee, lobby for political changes, enforce, and enact regulations. The FAA is NOT a military entity, but a civilian entity. Check out this home page and click the links of the top 25 people of the FAA. I don’t see a military guy in the bunch (excepting a rocket scientist and a Airforce cop). But I do see ALOT of industry experience!!!

Here is a parsed clip of what the FAA expects the successful candidate to possess to be a FAA inspector: “[B]Operations:[/B] Inspectors in this specialty apply knowledge and skills typically acquired as airmen (pilots, navigators, flight instructors, etc.), to develop and administer regulations and safety standards pertaining to the operation of aircraft. They engage primarily in the following types of assignments: (a) Examining airmen for initial certification and continuing competence; (b) evaluating airmen training programs, equipment, and facilities; and © evaluating the operational aspect of programs of air carriers and similar commercial and aviation operations for adequacy of facilities, equipment, procedures, and overall management to ensure safe operation of the aircraft. They may perform a variety of other inspections, investigations, and advisory duties. However, the primary requirement for positions in this specialization is knowledge and skill in the operation of aircraft.”

Now I get it. The USCG feels its members are our equals, and thus are experienced to know how to put their “knowledge and skills” to work to regulate the industry.

I think now may be the time to change the congressional mandate that allows this to continue.