Will the USCG turn OSV manning over on its head?

[B]United States Coast Guard Refines Requirements for Crew Rest on Ocean-Going Vessels[/B]

Thursday, October 25, 2012

Commercial vessels that operate beyond the internal waters of the United States, otherwise known as “beyond the boundary line,” are subject to the provisions of the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 (STCW).

This International Maritime Organization treaty was amended in 2010 to enhance the crew rest requirements for most ocean-going vessels. As a signatory to the STCW and its amendments, the U.S. is obligated to amend its national regulations to be consistent with the STCW. Although these regulations are not yet promulgated, the United States Coast Guard issued a policy letter (CG-CVC Policy Letter No. 12-05) on October 11, 2012, setting forth provisions and guidelines regarding crew rest consistent with the STCW and with a recommendation to U.S. flag vessels to employ the guidelines to avoid delay or problems when visiting foreign ports.

Crew fatigue has been identified as a causative factor in many major marine casualties over the years. As a result, the international maritime community established requirements in the STCW to limit crew work hours. These crew work rules, revised in 2010, direct that vessel operators crew each vessel with these requirements in mind. Further, the master is required to prepare and post work schedules accommodating crew rest requirements and record the daily periods of rest for each crewmember in the ship’s log or some other appropriate record. The United States Coast Guard policy letter sets forth these requirements in advance of the promulgation of regulations to implement the 2010 Amendments.

Since 1995, the international standard for crew rest has required all navigational and engineering watchstanders to rest for a minimum of 10 hours in any 24-hour period. The required rest period may be divided into two shorter periods, but one rest period must be of at least 6 hours duration. Watchstanders may not work more than 14 consecutive hours without a rest period absent emergency circumstances. During rest periods, crewmembers may not perform any work, including administrative tasks, such as preparing/reviewing documentation or correcting charts. Crewmembers must be permitted uninterrupted sleep during the rest period.

There are exceptions to these crew rest requirements. For instance, emergency situations and emergency drills may properly impede crew rest periods. Once an emergency period has concluded, the master shall ensure that each crewmember is provided adequate rest as soon as practicable. Crewmembers may be required to work on reduced rest due to exceptional circumstances, but the reduced rest periods must not exist for more than two 24-hour periods in any seven-day period. Under the revised rest rules crewmembers must be provided at least 77 hours of rest during any seven-day period. However, if emergency situations cause crewmembers to work under reduced rest periods, in no case shall a crewmember have less than 70 hours of rest in any seven-day period.

[B][I][U]These revisions to the STCW rest requirements, soon to be enacted into enforceable regulations by the U.S. Coast Guard, may well require adjustments to crew manning for some ocean-going vessels[/U][/I][/B]
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OK, all OSV’s are subject to STCW…can this really happen that the USCG will revisit the manning determinations for them? This could be BIG!

I didn’t read anything there that says 12/12 watch schedule isn’t acceptable. I’ve worked 6/6 and 4/8 before and that sucked. Why would they change it.

I have completely forgotten that OMSA will make darned well sure that the USCG maintains the status quo when it comes to OSV manning. For a minute there I was under a mistaken belief the Coast Guard would actually follow the letter of the conventions that they are signatory to…

…my stoopid!

Where does it imply a change would be needed? 12/12 exceeds the 10 hr rest/day minimum…am I missing something?

[QUOTE=rigdvr;86710]Where does it imply a change would be needed? 12/12 exceeds the 10 hr rest/day minimum…am I missing something?[/QUOTE]

I think it has to do with work done beyond the 12 hours of scheduled watch such as docking, undocking, cargo work. I thought about it afterwards and the way the GoM works, people pretty much do their 12 and disappear into their holes. It’s the tankers where this will more than likely make a big impact. No more working 48hours straight with the consequent loss of big OT $$$.

Roger that. With the majors requiring larger crews its not uncommon to have 2 officers per watch already but that varies per client request not regulation.

Seems they may be eyeballing the railroad industry in terms of crew rest and fatigue. D.O.T. remains the same with 12 hrs max time worked at one time but rest is a minimum of 10 hrs undisturbed. No paperwork, managers can’t call you, nothing. Work 6 days straight–48 hrs off, 7 days straight–72 hrs off, mandatory! No getting out of it. Probably won’t get that extreme, it’s not feasible. But I would expect some regulation about it in the future. Crew fatigue equals accidents in their minds.

All companies I have worked for ( all outside the US) mandate the STCW watch routine and the time sheets are filled in to follow that but
doesn’t work on a AHTS when you have the standard crew and do 24hrs of anchor handling. That’s why you have large luxurious sofa’s on the bridge of AHTS’s
Just another one of those forms you sign without reading when you walk into the crew mess
I remember one job that was signed IMCA compliant and the client had to agree to only use the vessel on DP for 12 hrs in every 24 to meet the crew requirement they were willing to pay for.

Explain why your vessel could only be in DP for 12 hours a day?

This is already being implemented in the APL and Matson fleets. Logs on the bridge and engine rooms to be filled out. There is the minor exception:
Crewmembers may be required to work on reduced rest due to exceptional circumstances, but the reduced rest periods must not exist for more than two 24-hour periods in any seven-day period. Under the revised rest rules crewmembers must be provided at least 77 hours of rest during any seven-day period. However, if emergency situations cause crewmembers to work under reduced rest periods, in no case shall a crewmember have less than 70 hours of rest in any seven-day period.

From personal experience in the China Loop, from Qingdao to Shanghai to Pusan, the rest requirement isn’t doable in Shanghai due to work/standby required and the short transit from Qingdao. Usually no/minimal OT before and after port. Not a whole lot different when OPA 90 came out. Always wondered what you guys in GOM did. Remember when I worked out there, you were on call even in excess of your 12 hours. Especially when tied up to the rig and in port. Do you guys even still tie off?

[QUOTE=RkyMtn Paul;86914] Remember when I worked out there, you were on call even in excess of your 12 hours. Especially when tied up to the rig and in port. Do you guys even still tie off?[/QUOTE]

Shallow water platforms and smaller vessels(<200’), YES. Deepwater (>200’) what is tieing off? Something I do when I shoot up?

Always wondered what you guys in GOM did. Remember when I worked out there, you were on call even in excess of your 12 hours.

This is why you make sure you have a good mate to relieve you. :stuck_out_tongue:

As long as the DP is working I have never tied off regardless of the depth of water and usually only when I’m pumping . Currently we are working in 40’ right off Grand Isle and the boat is 185’

[QUOTE=BMCSRetired;86949]Shallow water platforms and smaller vessels(<200’), YES. Deepwater (>200’) what is tieing off? Something I do when I shoot up?[/QUOTE]

The USCG D8 letter allows Hazardous and Oil Transfers to take place when in DP, and defined DP the same as being “moored” in respect to 33 CFR 156.120 - on the OCS, but that is not the case in state waters. It happens with vessels over 200 feet (at times) - with DP - “tying up” to a rig or facility due to being in state waters, because of regulation. That is just something to keep in mind, even though the larger vessel usually service deep water, and the smaller ones deal with shallow stuff.

Senior Chief, I was out there in 1990-91. Nearly all supply boats were 150’ +/- and there was not any DP. Nothing like trying to tie off a cement encrusted samson line on a H bitt in rough water. And, the rotations were 90/30 days.

Because you run out of working crew when anchor handling due to the extra guys on the bridge that would normally be sleeping and having 3 guys in the engine room and if the chief Eng runs the winch thats 8 engine staff on board to cover 24hrs

[QUOTE=RkyMtn Paul;86994]Senior Chief, I was out there in 1990-91. Nearly all supply boats were 150’ +/- and there was not any DP. Nothing like trying to tie off a cement encrusted samson line on a H bitt in rough water. And, the rotations were 90/30 days.[/QUOTE]

When I started in the late 70’s; Safety was a word in the dictionary, steel toes were for drilling rigs, work vests for working barges inland so you had a place to sit, and shoes and socks were for off the boat. I look back on that stuff now and I say to myself, “What the hell was I thinking?” Ah, the good old days.