Towing vessel manning.

[cappy208]

Looking for some definitive answers. (Mr Cavo perhaps?)

On a UTV, on a voyage from Fort Lauderdale to San Juan, Towing a petroleum barge. What are the manning requirements for a UTV over 100 tons (but under 200 tons) regarding vessel manning?

"(c) Subject to exceptions, 46 U.S.C. 8104(g) permits the officers and crew members (except the coal passers, firemen, oilers, and watertenders) to be divided into two watches when at sea and engaged on a voyage of less than 600 miles on the following categories of vessels:
(1) Towing vessel;..."

The voyage is approximately 980 miles. Does the Towing vessel have to have a three watch system in wheelhouse? Three watch on deck?



If the UTV is changed to a UTV over 200 tons are three watches required?
(Is there a change in requirements between the two categories?) Does the Officers Competency Convention Certification of '36 apply? Is this enforced?

§ 15.701 Officers Competency Certificates Convention, 1936.

(a) This section implements the Officers Competency Certificates Convention, 1936, and applies to each vessel documented under the laws of the United States navigating seaward of the Boundary Lines in part 7 of this chapter, except:
...
(4) A vessel of less than 200 gross tons.

And last but not least, is this an Ocean Voyage? (Requiring Oceans, or is NC enough?)

Where is this info specifically in the CFR's? There seems to be two areas that touch on this, 'Manning of towing vessels', and OCCC of '36. but both don't seem to agree, and there is confusion in the ranks.

Any help?

[cappy208]

No comments or thoughts on how to find the definitive answer?

[10talents]

I've only made one trip to PR and that to Ponce 32 years ago sailing on UTV with barge in tow. We sailed under 3 watch system for all departments.

[cmakin]

I don't know if they still do it, but back in the 80's, the Crowley tugs stood a three watch system on the Puerto Rico runs. In fact, I believe that all of their ocean tugs ran a three watch system in the deck department. With only one engineer, it was a bit different down below.

[cappy208]

I guess I was unclear in the original post. I am not so much concerned with what other companies are/have done, but what are the actual laws and requirements concerning this. Judging by the lack of info, it seems ALL are either not wanting to know, or apathetic about this.

Does anyone care to enlighten us on the USCG's policy of enforcement of manning of uninspected towing vessels? Especially in regards to voyages over 600 miles, on towing vessels over 200 GT.

This is another of those instances where if you look long enough and hard enough in the CFR's and US code you find TWO answers to the same question. Maybe since the USCG enforces (or not) these issues an answer could come from that side of the table?

[seadawg]

Does anyone care to enlighten us on the USCG's policy of enforcement of manning of uninspected towing vessels? Especially in regards to voyages over 600 miles, on towing vessels over 200 GT.

???last I checked..believe TV's over 200GT are considered "inspected"..if you are referring to UTV's (< 200GT) then your opening a "can of worms"..when it comes UTV's and USCG something very "magical and mystical" seems to transpire..kind of like the search for "unicorns"..hence the TOAR and the proposed vessel inspection program..this dilemma has been going on for 30+ years..

some history..back in the early 70's many "operators" weren't even "licensed" or even had a MMD..USCG waved their magic wand and poof!!you are now OUTV w/ a Zcard..many without the benefit of "testing"..key word "operator" therefore not quite a master..I was a OS w/ a Zcard before some tug captains/mates I worked w/ had a "license"..the present towing culture has "evolved" from this!!

back to the present: as it was explained to me by a "DESK pilot" the "3 watch system" as it applies to offshore tugs is more about liability and underwriter concerns rather than the confusion you are experiencing with the USCG regulation "mumbo jumbo"..therefore you will encounter ocean tows with crews numbering from 4 to 9 depending on how much of a "responsible carrier" the company is??this attitude is still prevalent!!

as side notes: there is report that some flag states are drawing exception to US Flag UTV's on foreign voyages that do not have "3 in the wheelhouse" and ALL crew members who are not STCW compliant..much of what is under scrutiny here is more about IMO/STCW violations and fines which are quick becoming a "cash cow" to many "3rd world ports"!!a licensed engineer is still not a requirement??also unless they recently changed it the tow from US port (Ecoast/GoM) to the US Commonwealth of Puerto Rico has always been "treated" as a "coastwise voyage"??

**with all that said..found these little "gems" in my personal archive:

http://www.uscg.mil/proceedings/arti...0guidebook.pdf

http://www.maritimeconsultant.com/ma..._towing_ve.htm

http://www.maritimeconsultant.com/ma..._towing_ve.htm

http://www.maritimeconsultant.com/ma...5/tugmanng.htm

http://www.maritimeconsultant.com/ma...Fall95/tug.htm

[injunear]

Towing vessels over 300T are inspected. Towing vessels over 200T (ocean and coastwise) require licensed engineer(s). Inland tugs over 300T require licensed engineer.

For the last 20 or so years that I was on wire boats, we had 3 watch in the wheel house on ocean and coastwise runs over 600 miles.

[seadawg]

For the last 20 or so years that I was on wire boats, we had 3 watch in the wheel house on ocean and coastwise runs over 600 miles.

for the most part that has been my experience as well..but have on occassion needed to remind management of a few "relative facts"..but the fact of the matter is that the UTV e/r to South America with just captain/mate/deck-eng/os as crew is still out there!!

[cappy208]

After MUCH searching I found this USCG explanation. http://towmasters.files.wordpress.com/2009/02/g-moc-pl-4-00_tv_watchkeeping.pdf

Perhaps Mr Cavo could figure out if this is still in force? Or has this been superseded or replaced by a newer letter?

Why is this info so hard to find?

This letter is almost so easy to read that it would take all the guess work out of the question...... Until one reads the last line on page 7. According to that NO one on a vessel over 100 tons is supposed to work over 8 hours a day!!

Why is this written in so many ways with NOT one clear answer?