Subchapter M


“Every SIRE I’ve had, was not nearly as thorough in training and the material condition of the vessel as a USCG inspection. It was all checking paperwork boxes and making sure the fire pump worked” thanks for gesticulating that your sire inspections involved you operating a fire pump, handy info indeed.

“Since the beginning that’s been an issue many in the industry have, on the crew side that is, have raised.” Well my point is exactly they didn’t listen to you.


“Taxes are why they have high gas prices.”

Taxes are A reason why they have gas prices.


A primary reason. If more tug and barges moving oil would lover gas prices on the west coast, believe the equipment is available.

You’re acting like it’s something new, and that we should be shocked that the government listened to the ship owners and not the sailors. As our industry has slipped father and father from the mainstream it’s only gotten worse. I reread “until the sea shall set them free” again last month and almost nothing has changed. When it comes to moving oil the majors generally want newer equipment. Some of that has to do with safety, but a lot of it has to do with lost time due to maintenance and breakdowns. The biggest thing they could go to improve safety is demand increased manning, absolutely number one. That’s not a tangibly and physically quantifiable thing to the average bean counter with no seagoing experience though. Unlike JSA’s, and graphs comparing downtime for a 45 year old tug and a 10 year old one.


I never expected that tugs were not inspected. What are the manning requirements or lack thereof at the root of the issue?


Two operators under 600 miles and three over 600 miles. The rest of the crew is up to the company.


Yup. Welcome to the club. Deep sea shipping has been going this route for a couple decades.

Embrace the suck!:metal:


The USCG and most companies have interpreted conflicting statutes and regulations to eliminate the 600 mile rule for tugs. See 46 CFR 15.705(d).

I rarely have two mates. Hence, 4 or 5 man boats are common on long voyages with long hitches.

Big boats owned by big companies, especially those towing oil barges, tend to have two mates.

Some companies are trying to hire licensed engineers. In theory they are required for voyages to Canada.

However, I’ve made several voyages to Canada in the last couple of years with just an unlicensed deck hand engineer without a problem.


Sub M manning charts have been out for a while.


At one point a few years ago, there was a GMDSS scare for US companies sending tugs to Canada. Some companies started asking guys for GMDSS certificates so they could go to Canada. But nothing ever came of it, at least not in British Columbia.


Do you have a Link for these Charts on Manning under Subchapter M? I’ve searched and can’t find anything definitive on manning scales.


I cannot find any minimum manning for tugs under Subchapter M in the CFRs.

Where did you find this Subchapter M manning chart?

The COIs for tugs start for new tugs now, and 25% of an owner’s existing tugs on 22 July 2019. The one boat companies have until 2020. There is suppposed to be 100% COI coverage by 22 July 2022.

You watch —- the AMO will claim the boats are safe enough, the USCG will claim that they don’t have a big enough budget —- COIs under Subchapter M will get pushed back a few more years.

Tugs under 100 Tons should have been inspected under Subchapter T —-40 years ago.

Other Tugs should have been inspected under Subchapter I —-40 years ago.

Tugs pushing/Towing oil should have been inspected under Subchapter D —-40 years ago.

Subchapter M is a total bullshit.


That may be because SIRE is not about “material condition of the vessel” but about operational and safety issues.
Only members (Oil companies) can commission a SIRE (or OVID) inspection through OCIMF, who then appoint an inspector.
The inspectors are mostly independent Surveyors, some with affiliations with one or more Marine Consultant company, but rarely an employee of an Oil company.

If anybody want to know more about OCIMF, SIRE or OVID, check out the websites I linked to in Post#11


See 46 CFR 136.205.

A towing vessel’s COI shall specify the routes, Manning, and equipment “as determined by the OCMI”.

I guess what will be required for a COI under Subchapter M depends upon whom the OCMI plans to work for after he “retires” from the USCG at age 38.


Loadlines 136.250

Tugs built before 1968 and under 79 feet and 150 GRT do NOT require loadlines on International voyages.

Tugs built before 1986 and under 79 feet and 150 GRT do NOT require loadlines on Domestic voyages.

So there is an incentive and value to keeping these small old boats in operation.

Some companies, especially Crowley, built some really nice tugboats in the 60’s, 70’s, and 80’s, and some of them have been updated and are still in good shape, often under proud new ownership.

There are a few “historic” old tugboats in marginal condition that should be allowed to continue with limited operations.

However, most of these old “rulebeater” tugboats from the 40’s, 50’s, 60’s, 70’s and 80’s, that have supposedly been “rebuilt” and are still in service are old, halfass, patched up, worn out, under-equipped, junk.

When are they going to be required to have loadlines or be phased out?


I think inland tugs only require 2 licensed wheelman regardless of route length. Maybe once you go near coastal you need another license for over 600 miles. To my understanding, this doesn’t exist inland or at least the companies don’t pay attention to it.


It doesn’t exist anywhere


I highly doubt any inland tug does a non stop voyage of more than 600 miles. (If they ever do it’s so rare no one pays attention.)


It’s hit or miss. A couple years ago Signet wanted to do a trip from Pascagoula to Mexico and the local USCG wouldn’t let them without running three watches. They tried saying they were going to Brownsville first and doing “two voyages” but the USCG wouldn’t buy it. The guys I talked to there were pissed because they thought that meant having 9 people onboard and the boats aren’t that big. No one believed me when I said you only needed 6 people to run three watches…


See 46 CFR 15.705(d). It doesn’t matter what some incompetent local USCG officer thinks.

Two mates are never required on voyages over 600 miles.


Check your citation again please. As far as I can see there is no 15.075…