Manning & Watch Keeping Uninspected Towing Vessels

Towing Vessel Manning Learning Objectives State: manning and work hour requirements for UTV operating on inland waters. State: manning and work hour requirements for UTV operating outside the boundary lines. State: manning requirements for vessels on international voyages. State: manning requirements for vessels on for vessels on foreign voyages.

Manning Responsibility Towing Vessel Manning Manning Responsibility 46 CFR 15.103(b) “The navigation and shipping laws state that a vessel may not be operated unless certain manning requirements are met. In addition to establishing a minimum of licensed individuals and members of the crew to be carried on board certain vessels, they establish minimum qualifications concerning licenses, citizenship, and conditions of employment. It is the responsibility of the owner, charterer, managing operator, master, or person in charge or command of the vessel to ensure that appropriate personnel are carried to meet the requirements of the applicable navigation and shipping laws and regulations”

Towing Vessel Manning Master 46 CFR 15.805 The mariner must hold one of the following : Master of towing vessels; or Master of inspected, self-propelled vessels of greater than 200 gross register tons, may operate towing vessels within any restrictions on their license, if they— (a) Have 30 days of training and observation on towing vessels for the route being assessed (90 days for the Western Rivers) and, Either— (1) Hold a completed TOAR; or (2) Complete an approved training course. 46 CFR 15.805

Towing Vessel Manning Mate (Pilot) 46 CFR 15.810 (d) The mariner must hold one of the following: Mate of towing vessels; or Mate of inspected, self-propelled vessels of greater than 200 gross register tons or first-class pilot, may operate towing vessels within any restrictions on their license, if they— (a) Have 30 days of training and observation on towing vessels for the route being assessed (90 days for the Western Rivers) and, Either— (1) Hold a completed TOAR; or (2) Complete an approved training course. 46 CFR 15.810 (d)

Pilotage Requirements Towing Vessel Manning Pilotage Requirements

Pilotage Lower Mississippi River Must have: Master or Mate (Pilot) with First Class Pilot endorsement for the route or Western Rivers endorsement OR With Tank Barges - 12 round trips with 3 during darkness and 1 within last 12 months With out barges or with uninspected barges – 4 round trips with 1 during darkness and 1 within last 12 months Tank Barges Greater than 10,000 in pilotage waters – First Class Pilot Required (COI authorize service beyond the boundary lines Tank Barges Greater Than 10.000 GRT. Non designated areas., Master, Mate, or Master, Mate(pilot) of towing vessel may serve as pilot with in the 3 mile line and the start of traditional pilot route. (COI authorizes service beyond the boundary lines) Tank barges l0,000 GT or less in pilotage water – Master, Mate or Master, Mate (Pilot) of towing vessel may serve as pilot.(COI authorizes service beyond the boundary lines) The Tank Barge COI is the key, if the COI authorizes service beyond the boundary lines then the First Class Pilot issue may be come into play if the barge is operated pilotage areas and if the barge is greater than 10,000 GT. 46 CFR 15.610 (b)(1)(2)

Pilot General Master, Mate… of towing vessels may serve as pilot if the individual: Is 21 years old. Has annual physical.. Maintains current knowledge of the waters. Has at least 6 months service in the deck dept on towing vessels. Has 12 round trips over the route. Tank Barges 10,000 GT or less… Tank Barges Greater than 10,000 in pilotage waters – First Class Pilot Required (COI authorize service beyond the boundary lines Tank Barges Greater Than 10.000 GRT. Non designated areas., Master, Mate, or Master, Mate(pilot) of towing vessel may serve as pilot with in the 3 mile line and the start of traditional pilot route. (COI authorizes service beyond the boundary lines) Tank barges l0,000 GT or less in pilotage water – Master, Mate or Master, Mate (Pilot) of towing vessel may serve as pilot.(COI authorizes service beyond the boundary lines) The Tank Barge COI is the key, if the COI authorizes service beyond the boundary lines then the First Class Pilot issue may be come into play if the barge is operated pilotage areas and if the barge is greater than 10,000 GT. 46 CFR Table 15.812(e)(2)

Towing Vessel Manning Chief Engineer Individuals engaged or employed to perform the duties of chief engineer must hold appropriately endorsed license or MMC authorizing service as a chief engineer Required on uninspected , seagoing, documented vessels of 200 GT or more License must be appropriate for route, size and horsepower of vessel Most seagoing Uninspected Towing Vessels are specifically built and admeasured to be less than 200 GT. There must be an individual holding an MMC or licensed endorsed as chief engineer OR OTHER CREDENTIAL AUTHORIZING SERVICE AS CHIEF ENGINEER ON 46 CFR 15.820 (b)

Towing Vessel Manning Who Can Serve as Chief Engineer? Designated Duty Engineers (DDE) DDE – limited to not more than 1000/4000 HP on Near Coastal, Great Lakes & Inland Waters. DDE Unlimited my serve on any waters. Limited to Vessels not more than 500 GT Chief Engineer (limited-oceans) Service on vessels AGT on Inland Waters Service on vessels not more than 1600 GT on Near Coastal or Great Lakes . There must be an individual holding an MMC or licensed endorsed as chief engineer OR OTHER CREDENTIAL AUTHORIZING SERVICE AS CHIEF ENGINEER ON 46 CFR 15.915

Towing Vessel Manning Who Can Serve as Chief Engineer? Chief Engineer (limited – near coastal) Service on vessels AGT on Inland Waters Service on vessels not more than 1600 GT on Near Coastal or Great Lakes . Assistant Engineer (limited-oceans) Service on vessels not more than 1600 GT on Oceans, Near Coastal or Great Lakes . There must be an individual holding an MMC or licensed endorsed as chief engineer OR OTHER CREDENTIAL AUTHORIZING SERVICE AS CHIEF ENGINEER ON 46 CFR 15.915

Watchkeeping & Work Hours 46 CFR 15.701 46 CFR 15.705 46 CFR 15.710 46 CFR 15.715 46 CFR 15.840 USC 8104 SOLAS Chapter V, REG. 14 IMO Resolution A.1047 (27) - 30NOV2011 IMO Resolution A.890(21) - Revoked IMO Resolution A.955(23) - Revoked STCW Regulation VIII/2

Towing Vessel – Work Hour Inland and Great Lakes Gross Tons Route Length of voyage Wk Hr. Limits Cites Less than 100 Inland Any Length 12 Hours 46 CFR 15.705 (d) 46 USC 8104 (b)(h) GL 8/12/15 Hours 46 USC 8104 (c) More than 100 46 USC 8104 (c) (d) 100-200 More than 200 46 CFR USC 8104 (h)

Towing Vessel – Work Hour Oceans Gross Tons Route Length of voyage Wk Hr. Limits Cites Less than 100 Oceans Less than 600 NM 12 Hours 46 CFR 15.705 (d) 46 USC 8104 (b)(h) More than 600 NM 100-200 46 USC 8104 (g)(h)(d) 46 USC 8104 (h)(d) More than 200 8 Hours

Watches Watches on voyages less than 600 nm are permitted to be a two (2) watch system Watches on voyages more than 600 nm must be a three (3) watch system 46 CFR 15.705

Watches The Coast Guard interpretation of USC 8104 (h), in conjunction with other provisions of the law, to permit masters or mates (pilots) serving as operators of towing vessels that are not subject to the Officers’ Competency Convention , 1936 to be divided into two watches regardless of the length of the voyage. 46 CFR 15.705 (d)

Manning Requirements AB’s Two Watch System Three Watch System Six (6) on six (6) off schedule 50% of deck crew must be AB’s Does not include licensed officers Four (4) and eight (8) schedule 65% of deck crew must be AB’s Does not include licensed officers 46 CFR 15.840 USC 8702

Able Body Seaman AB Unlimited - Service on any vessel AB Limited - Service on vessels less than 1600 GT* AB Special – Service on vessels less than 500 GT* AB OSV – Service on OSV’s less than 500GT AB Sail – Service on sailing School vessels AB Fishing – Service on fish processing vessels * May constitute not more than 50% of the number of AB’s required on other vessels 46 CFR 15.840 USC 8702 USC 7312

STCW Basic Safety Training Seagoing Vessels Communication Muster stations, escape routes Fire, man overboard, and fire alarms Locate and don PFD’s Knowledgeable of the fire and WTD’s ETC. 46 CFR 15.1105

Watchkeeping STCW Requirements Verify that the “STCW Principals of Watchkeeping” are being observed 46 CFR 15.1109

STCW Principals of Watch Keeping Each master of a vessel that operates beyond the Boundary Line shall ensure observance of the principles concerning watch keeping set out in STCW Regulation VIII/2 and section A-VIII/2 of the STCW Code. 46 CFR 15.1109

STCW 95 Rest Period Requirements Officer in charge Navigation/ Engineering Watch: Minimum of Ten (10) hours of rest in a 24 hour period Hours of rest may divided into no more than two (2) periods Need not be maintained in case of emergency, drills or overriding operational conditions. Personnel remain subject to the work-hour limitations in 46 USC 8104 46 CFR 15.1111

Safe Manning Issues Towing Vessel Detentions Flag States unfamiliarity with Uninspected Towing Vessels and US domestic regulations that apply to these vessels. Vessel Operators unfamiliar or unaware of safe manning requirements USCG inconsistent application of safe manning principals and requirements 1. UTV’s less than 200 GRT are specifically authorized to utilize a two-watch system regardless of the length of the voyage, when operating domestically 2. The USCG has interpreted the guidance in IMO Resolution A.890(21) to require a three watch system on international voyages 3. 46 CFR 24.05-1, note (6) requires utv’s on international voyages to comply with SOLAS, SOLAS, Regulation 14 1 states that all Ships (includes UTV) shall be sufficiently and efficiently manned and foot note refers to the Principles of safe manning adopted by IMO A.890(21), as amended by resolution A.955 (23)  

Safe Manning International Voyage A voyage between a country to which SOLAS applies and a port outside that country. For the purposes of this subchapter, vessels are not considered as being on an "international voyage" when solely navigating the Great Lakes and the St. Lawrence River as far east as a straight line drawn from Cap des Rosiers to West Point, Anticosti Island and, on the north side of Anticosti Island, the 63rd meridian 1. UTV’s less than 200 GRT are specifically authorized to utilize a two-watch system regardless of the length of the voyage, when operating domestically 2. The USCG has interpreted the guidance in IMO Resolution A.890(21) to require a three watch system on international voyages 3. 46 CFR 24.05-1, note (6) requires utv’s on international voyages to comply with SOLAS, SOLAS, Regulation 14 1 states that all Ships (includes UTV) shall be sufficiently and efficiently manned and foot note refers to the Principles of safe manning adopted by IMO A.890(21), as amended by resolution A.955 (23) 46 CFR 24.10-1  

Safe Manning Foreign Voyage A vessel engaged on a foreign voyage means a vessel to which this chapter applies arriving at a place under the jurisdiction of the United States from a place in a foreign country making a voyage between places outside the United States; or departing from a place under the jurisdiction of the United States for a place in a foreign country. 1. UTV’s less than 200 GRT are specifically authorized to utilize a two-watch system regardless of the length of the voyage, when operating domestically 2. The USCG has interpreted the guidance in IMO Resolution A.890(21) to require a three watch system on international voyages 3. 46 CFR 24.05-1, note (6) requires utv’s on international voyages to comply with SOLAS, SOLAS, Regulation 14 1 states that all Ships (includes UTV) shall be sufficiently and efficiently manned and foot note refers to the Principles of safe manning adopted by IMO A.890(21), as amended by resolution A.955 (23) 46 USC 32.01  

Safe Manning Domestic Voyage Domestic voyage means “movement of a vessel between places in, or subject to the jurisdiction of, the United States, except movement between— a place in a territory or possession of the United States or the Trust Territory of the Pacific Islands; and a place outside that territory, possession, or Trust Territory.” 1. UTV’s less than 200 GRT are specifically authorized to utilize a two-watch system regardless of the length of the voyage, when operating domestically 2. The USCG has interpreted the guidance in IMO Resolution A.890(21) to require a three watch system on international voyages 3. 46 CFR 24.05-1, note (6) requires utv’s on international voyages to comply with SOLAS, SOLAS, Regulation 14 1 states that all Ships (includes UTV) shall be sufficiently and efficiently manned and foot note refers to the Principles of safe manning adopted by IMO A.890(21), as amended by resolution A.955 (23) 46 USC 5101  

Safe Manning Domestic manning requirements and international manning requirements may be significantly different. IMO Resolution A.1047 (27) provides international guidance on safe manning and require a 3 watch system with certain exceptions. Principles of Safe Manning Apply to All Vessels UTV’s , regardless of size. when on international voyages 1. UTV’s less than 200 GRT are specifically authorized to utilize a two-watch system regardless of the length of the voyage, when operating domestically 2. The USCG has interpreted the guidance in IMO Resolution A.890(21) to require a three watch system on international voyages 3. 46 CFR 24.05-1, note (6) requires utv’s on international voyages to comply with SOLAS, SOLAS, Regulation 14 1 states that all Ships (includes UTV) shall be sufficiently and efficiently manned and foot note refers to the Principles of safe manning adopted by IMO A.890(21), as amended by resolution A.955 (23)  

Safe Manning Document Keels Laid on/after 28 July 1994 Required on vessels of 500 GT ITC and above Recommended on vessels less than 500 GT ITC On international voyages Keels Laid before 18 July 1994 Not required Highly recommended 3-watch system required Ref: SOLAS – Chapter V, Regulation #14 46 CFR 24.05-1 (a) (footnote #6) 1. The Principles of safe manning apply to all vessels regardless of size. (IMO Resolution A.890(21) as amended (IMO Resolution A.955 (23) 2. The Requirements to possess a Flag State issued SMD only applies to vessels of which Chapter I of SOLAS applies (vessels built after July 1994  

Safe Manning Policy & Guidance IMO Resolution A.1047 (27) Marine Safety Manual, Volume III  

Safe Manning Document - SMD - Flag-state authorization to deviate from a 3 watch System Provides port-states with flag-state’s vessel specific manning levels For inspected vessels, the vessel’s COI is the SMD  

Safe Manning Document Exercise Manning – Ocean Navigator Build Date 1986 GRT – 195 GT ITC – 565 HP/kW – 6000/4662  

Safe Manning Document Ocean Navigator  

Great Lakes & Inland Manning Summary Vessels 26 ft. and greater Master required on board Mate required when the vessel operates more that 12 hrs. No requirement for Engineering Officer No minimum number of deck required AB’s required on Great Lakes (Based on watch system, I.E. 2 or 3 watch system) AB’s not required on Inland waters No international requirements  

Near Coastal & Oceans Manning Summary Less than 200 GT & 26 ft. and greater Master required on board Mate required when the vessel operates more that 12 hrs. No requirement for Engineering Officer No STCW requirements No minimum number of deck required AB’s required on vessels 100 GT and greater (based on watch system, I.E. 2 watch or 3 watch system) International conventions may apply  

200 GT but < 300 GT & >/= 26 ft Oceans Manning Summary 200 GT but < 300 GT & >/= 26 ft Master required on board Mate required when the vessel operates more that 12 hrs. Engineer Required Meet STCW 95 requirements No minimum number of deck required AB’s required on vessels 100 GT and greater (based on watch system, I.E. 2 watch or 3 watch system) International conventions my apply based on appropriate tonnage convention  

Manning Rules Summary All UTV’s on International Voyages are subject to the requirements of The International Convention for Safety of Life at Sea, 1974 (SOLAS) Any UTV Operating outside the boundary lines are subject to the STCW requirements  

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