USCG 12 Hour rule interpretation

Maritime Topics Tugs & Towing
1

Hello folks, I’m looking to understand the USCG 12 Hour Rule.

A quick google search for “uscg 12 hour rule” hits this document right away:

G-MOC POLICY LETTER 4-00, REV-1

I’m specifically looking into Inland/NC towing vessels less than 200GRT.

#3 Watchkeeping > paragraph F says:

46 U.S.C §8104(h) establishes that licensed operators of towing vessels subject to 46 U.S.C.
§8904 may not work in excess of 12 hours in any consecutive 24-hour period, except in an
emergency.

So that’s pretty straight forward:
[ul]
[li]operators may not work more than 12 hours in the last 24 hours[/li][/ul]

Then we get into some STCW requirements. If the tug is Uninspected, maybe the STCW requirements don’t apply?* But if they did, we have additional requirements for “both short and long term rest requirements for watchkeeping personnel.”
[ul]
[li]all engineers and watchkeepers shall receive 10 hours of rest in any 24-hour period[/li][li]hours of rest must be in no more than 2 chunks, one of which must be at least 6 hours[/li][li]10 hours rest can be reduced to 6 consecutive hours rest so long as:[/li][LIST]
[li]this reduction does not repeat longer than 2 days AND[/li][li]70 hours rest per 7-day period must be met[/li][/ul]
[/LIST]

I’m looking for any rewording, or corrections to my interpretations above.

So the culmination of this inquiry and work is going to be a Google Doc spreadsheet where operators can input the work they do, and be told by that spreadsheet if they are “out of hours” and how long of a rest period they are required to take. I think it would be neat if, in addition to the Policy Letter the USCG released, they released a downloadable spreadsheet that did just what I said. Or better yet, an app. A USCG app. That would be slick.

After this project, if anyone is interested in getting a copy of the spreadsheet, message me and I’ll be happy to oblige.

The United States exempts mariners from STCW requirements ifserving on vessels of less than 200 gross tons sailing on near coastal domestic
voyages.
document pg16 UTVGUIDEBOOK PDF

2

[quote="“mrdrew”"]
Hello folks, I’m looking to understand the USCG 12 Hour Rule. A quick google search for “uscg 12 hour rule” hits this document right away: G-MOC POLICY LETTER 4-00, REV-1 I’m specifically looking into Inland/NC towing vessels less than 200GRT. #3 Watchkeeping > paragraph F says: So that’s pretty straight forward: [li]operators may not work more than 12 hours in the last 24 hours Then we get into some STCW requirements. If the tug is Uninspected, maybe the STCW requirements don’t apply?* But if they did, we have additional requirements for “both short and long term rest requirements for watchkeeping personnel.” []all engineers and watchkeepers shall receive 10 hours of rest in any 24-hour period []hours of rest must be in no more than 2 chunks, one of which must be at least 6 hours []10 hours rest can be reduced to 6 consecutive hours rest so long as: []this reduction does not repeat longer than 2 days AND [*]70 hours rest per 7-day period must be met I’m looking for any rewording, or corrections to my interpretations above. So the culmination of this inquiry and work is going to be a Google Doc spreadsheet where operators can input the work they do, and be told by that spreadsheet if they are “out of hours” and how long of a rest period they are required to take. I think it would be neat if, in addition to the Policy Letter the USCG released, they released a downloadable spreadsheet that did just what I said. Or better yet, an app. A USCG app. That would be slick. After this project, if anyone is interested in getting a copy of the spreadsheet, message me and I’ll be happy to oblige. * document pg16 UTVGUIDEBOOK PDF[/li][/quote]
don’t be a cheapskate and buy accepted software to handle this automatically. But that software is easily defeated to keep management happy, FYI. Apps are good, but now you’ll just get Mariners in trouble, OR, make them lie. Anyone who works 6/6 knows you can’t comply with STCW in getting 6 hours rest daily. It’s a goddamn joke. But the customers don’t care, and only the customers will make a change.

By time you spank the monkey, take a shower, do dishes, or make a coffee. You’re taking maybe 5 hours of rest at the best.

3

[QUOTE=z-drive;164177]
By time you spank the monkey, take a shower, do dishes, or make a coffee. You’re taking maybe 5 hours of rest at the best.[/QUOTE]

Don’t forget about arguing with the wife, lecturing the kids for giving mom a hard time, and online banking. Some of us have to go out to sea to get rest.

4

They already have a program for this

5

and it sucks! You either have to lie or get shit from the office. The conclusion is the 2 watch system is broken if you want to comply with STCW.

6

No it’s not, just work 12 hour watches and get 10 hours of sleep like the rest of us.

7

[QUOTE=Fraqrat;164240]No it’s not, just work 12 hour watches and get 10 hours of sleep like the rest of us.[/QUOTE]

That would be great if they would NEVER wake you up off watch. I believe that your are a Chief can you tell us that you are NEVER awaken for a problem? If you say NO, you are either lying or you have the Best Group of Assistants ever put together.

8

What about when the boats in the corners maneuvering, line jumping on the bit when doing an assist job, fucking around with breaking/remaking tow? Tough to sleep through even if you’re not needed.

9

Of course I get woke up randomly or have to stay up late for a repair. I also do have a fantastic group of assistants/QMEDS so they don’t wake me up for every little thing. When I say randomly I’m talking once or twice in a 21 day hitch. Unless it’s a big “boat is shut down” issue I can go back to sleep and get plenty of rest. Unless the wx is bad and the thrusters are ramped over 60% I don’t hear shit in my room. It’s so quiet I have a box fan going just to drown out the sounds of people in the passageways.

10

Nice, I figured someone had already come up with a solution to the 12-hour-rule: and charged for it.

6/6, I’ve stood them, and absolutely, 5 hours of sleep during a 6 hour rest period. Too bad there weren’t 26 hours/day, then we could get our 6 hours rest period.

I’m just talking documentation of complying with the rule. What one does with that information is up to them - but it would be nice to know.

Thanks everyone!

11

I wil say my current room is very quiet and everyday noises do not register, but I think for every one of us that lucky there are ten guys who aren’t. We don’t get each other up, but just the principle of 6/6 is the problem. No way to et the whole 6 hours of required rest when you’re off watch for only 6 hours.

That’s one reason we break watch whenever we can, no reason for more than one person to be up a 0200 when you’re alongside a dock.

12

[QUOTE=mrdrew;164247]Nice, I figured someone had already come up with a solution to the 12-hour-rule: and charged for it.

6/6, I’ve stood them, and absolutely, 5 hours of sleep during a 6 hour rest period. Too bad there weren’t 26 hours/day, then we could get our 6 hours rest period.

I’m just talking documentation of complying with the rule. What one does with that information is up to them - but it would be nice to know.

Thanks everyone![/QUOTE]

Documentation is not difficult. Each crew has a worksheet and he marks the hours worked. It gets signed and filed.

The issue is how to tell if there is a violation or not. It relatively easy to check compliance with the six hour rule but the 70 hr in 7 days takes a litte more work. The other issue is that the rest periods are not starting every day at midnight but are in any 24 hr rolling period.

There are some software solutions out there. Watchkeeper is the most sophisticated one I"ve seen.

Also there is nothing in the work/rest rules about sleep. If you are off the clock it is a rest peroid regardless if you get any sleep or not.

13

At sea I probably get 11 hours off each day. I sleep five hours between midnight and 0600. In the afternoon I usually sleep two hours. That’s enough. Port calls and river transits can make for some very long days.

There is no way that a two watch system can comply with the STCW hours of rest rules. Everyone knows that.

That’s why STCW rules will not apply to 99 percent of Jones Act tugboats, until after the next big accident where lack of rest was a major factor.

The best cure for this problem would to require the companies to pay time and a half after 8 hours, and double time after 12 hours and triple time after 15 hours, and quadruple time after 18 hours. That would get us back to 10 man crews, including a cook and two ordinaries, pretty damn quick.

14

[QUOTE=tugsailor;164254]At sea I probably get 11 hours off each day. I sleep five hours between midnight and 0600. In the afternoon I usually sleep two hours. That’s enough. Port calls and river transits can make for some very long days.

There is no way that a two watch system can comply with the STCW hours of rest rules. Everyone knows that.

That’s why STCW rules will not apply to 99 percent of Jones Act tugboats, until after the next big accident where lack of rest was a major factor.

The best cure for this problem would to require the companies to pay time and a half after 8 hours, and double time after 12 hours and triple time after 15 hours, and quadruple time after 18 hours. That would get us back to 10 man crews, including a cook and two ordinaries, pretty damn quick.[/QUOTE]

I worked that same rotation for 17 years. 6&6 with OT off watch or out of dept. OT was 1/8th day rate, penalty OT was 1/12th.

I’ve beed retired 6 years but still have to get my afternoon nap.

15

No doubt that 6/6 sucks but a 12 hour watch towing a barge up the beach or pushing it down a river would suck more. Its not so bad ship docking though.

We do the same thing if we are at the dock. We split the watch to get those few extra hours of sleep.

16

My Old Company used a Spread Sheet that would turn the number RED if you went over your hours for either a day or the total allowed for a time period.

One time I got a call from the Office and was asked to explain how I was going over my hours. My watch was 0600-1200 / 1800-2400. They got very quite when I told them things like this as they called at 1400 and I was awakened to take the call. They did not see the Humor when I told them that I am now over for that day now due to being CALLED OUT to take the call. After all fair is fair.

17

[QUOTE=Kennebec Captain;164249]Also there is nothing in the work/rest rules about sleep. If you are off the clock it is a rest peroid regardless if you get any sleep or not.[/QUOTE]

While you beat me to it I’m not sure this registered with people. Under the STCW rule, “rest” does not mean SLEEP.

18

[QUOTE=Capt. Phoenix;165512]While you beat me to it I’m not sure this registered with people. Under the STCW rule, “rest” does not mean SLEEP.[/QUOTE]

Therefore, the two watch system working 6x6 is perfectly legal by all rules currently in place (USCG and STCW).

19

[QUOTE=Capt. Phoenix;166010]Therefore, the two watch system working 6x6 is perfectly fine by all rules currently in place (USCG and STCW).[/QUOTE]

On paper it is.

20

[QUOTE=Tugboater203;166016]On paper it is.[/QUOTE]

Of course I’m assuming you don’t get called out off watch for non emergency issues.