The TOAR: what's it for?

**captjacksparrow** · December 11th, 2008, 02:37 PM

The Towing Officers Assessment Record (TOAR) is the "manual" used to guide and document the practical assessment of a mariner attempting to qualify as a towing vessel deck officer (Master, Mate or Pilot). It was created because of the known shortcomings of the system as it was.
The present official qualification process for towing vessel deck officers is comprised of two parts.
1. The Coast Guard tests the license candidate's "book knowledge" by administering a multiple-choice written examination. Call it an intelligence test, if you like. Everyone knows that passing a multiple-choice exam alone has little bearing on whether an individual can actually physically perform the job. But, for the most part, it is still very necessary to possess and demonstrate that you have that knowledge by passing the test. You certainly aren't to learn about stability by osmosis while standing on deck. Having said that, the Coast Guard's question pool needs a serious vetting by experienced towing vessel officers and should be reviewed regularly for continued relevance. Otherwise it gradually loses its usefulness and mariners come to regard it as bureaucratic bullshit with no real value.
2. The C.G.-certified towing vessel Designated Examiners then use the TOAR to guide them while they observe and sign-off the candidates as they actually perform the required practical tasks. These practical assessments evolved out of the knowledge that passing multiple-choice written exams was terribly insufficient and without the assessments the Coast Guard would have no way of knowing if an individual was truly competent or not. The old way of simply letting each captain who was breaking someone in determine when someone was ready or not, based on their own standards, led to very inconsistent results. Being a skilled captain does not necessarily mean that you will be a good teacher. I've often heard captains say "I don't bother with that, it doesn't matter" when referring to some particular task that they don't feel is important. Often this was a technical subject that they knew little or nothing about, thus it didn't matter. The TOAR was meant to give structure to a formerly unstructured process, and take the personal preferences, prejudices, subjectivity and guesswork out of the equation. Nothing will ever completely eliminate it but a well designed TOAR will minimize it.
There is a third "unofficial" part to the process that is not directly mandated by any law or regulation:
3. The companies that own and operate the tugs and towboats should carefully screen and evaluate those who they allow to operate their vessels. Many of them go to great lengths to ensure competency. Some are, to varying degrees, less diligent about it. And some are fly-by-night all the way. Think DRD Towing. Think the T/V Mauvilla (Amtrak Disaster in Alabama). Think about the many others that never made the news because, by luck alone, no one got killed. In any case, unless a given company's Port Captains are former captains (skilled and competent captains, that is) they may have great difficulty in making an informed decision. That is not always the case and quality varies widely.
With all this in mind it is clear, to me at least, that the TOAR is the one major part of this process that's almost completely in our hands for ensuring quality control, no matter how ridiculous the regulations may be. It needs to be the best it can be, it needs to be embraced by all of us, and it needs to be strictly enforced by us so that the regulatory lobbying by AWO doesn't further undermine the standards. The remainders of the old Tugasaurus attitude that it's all a bunch of bullshit needs to be eradicated as well.
The PMI TOAR that I and the other MTVA members reviewed and made additions to is very comprehensive. I've heard the complaints about it being too long, complicated or difficult and I don't buy it. In fact, I think that the entire licensing and qualification process should be primarily TOAR-driven. What I mean by that is that the license itself, and all the parts of the TOAR other than the Maneuvering section, should essentially serve as the "cover charge" for entry to the wheelhouse. The Maneuvering section of the TOAR should be used to determine what evolutions you should or should not be allowed to do, based upon whether you've satisfactorily performed them and been signed off. In that way, you only need to be signed off for what you do in your operation, and the maneuvers you don't do don't need to be signed off. If you change boats or jobs and get involved in doing maneuvers and operations you've never done before then you would need to be signed off by a DE for them before being cut loose, no matter whether you're a master or mate. This would be the easiest way to provide adequte guidance and ensure competence without either burdening mariners with lots of tasks they'll possibly never perform or having to make do with the very simplistic Maneuvering section of the original 2001 TOAR.
And I still respectfully, and very forcefully, disagree with both anchorman and Capt. Doug Pine. When you have people lateraling over into towing with >200GRT licenses from other sectors, they take no tests and the C.G. has no direct oversight of them. All they need is 30 days and the TOAR. For the <200GRT crowd they take a limited exam and are supposedly "experienced" because they must have 3 years of 8-hour days on their license, plus the 30 days and a TOAR. But it matters not at all where that "experience" was obtained, and only someone who has no direct knowledge thinks that this other "experience" is actually worth much on a tug. So it's completely up to the DE's and the companies. We've seen what can happen when you leave it only to the companies, so the DE's are truly the last line of defense. If the person getting signed off already holds a license as Master, then upon completion of the TOAR they are right then and there immediately authorized to serve as a Master of Towing Vessels, with no supervision and no further review required by anyone, based on your signature. So, anchorman, when you say that when you sign off on such a person that you're "not attesting to anyone's ability to serve as a Master" that's really skating around the issue on legal technicalities, and that ice is pretty damn thin. Do you really think that you would be protected from the civil lawsuits that would undoubtedly result after a major calamity resulting in civilian deaths and involving a 30-Day Wonder (or even someone that took the Apprentice Mate / Steersman route) that you signed off on? I sincerely doubt it, no matter what the CG says about it.

**dougpine** · December 11th, 2008, 02:57 PM

It is important I think to emphasize the difference between the legal and practical sides of this discussion as they relate to a DE's liability. I was refering, in a legal sense, to the fact that a DE is not attesting to one's ability to serve as Master. I was focusing on a liability issue, not a practical one. I am in complete agreement with CJS that the DEs are the last line of defense with regard to the 30 day wonders.
I'm no fool, I realize that in some regions the 30 day wonder is a blessing to companies with less stringent requirements for their Masters. In those cases you're absolutely right, it is the DEs who will need to draw the line and keep from signing these guys off too quickly. But even if they do sign them off, from a legal perspective they do not open themselves up to liability unless is can be show that they have fraudulently signed off the TOAR.
Practically speaking, no DE I know is going to sign off a licensed guy lateraling over to tugs in 30 days. He's barely going to become familiar with the vessel systems in 30 days let alone become a tug boat operator. Even if he has a license, under or over 200 GRT, if he's with me it is going to take probably eighteen months. At the end of that eighteen months if he's an exceptional case he just may have the skills to sail as Master, depending of course upon they vessel, route, and type of tow. However, in my company at least, there's no way he's going to be sailing as Master, even though he may technically be qualified to do so, for years and then only after months and months sailing as a training Master.

**jdcavo** · December 11th, 2008, 05:35 PM

"Having said that, the Coast Guard's question pool needs a serious vetting by experienced towing vessel officers and should be reviewed regularly for continued relevance."
Are you volunteering? The questions are available at http://www.uscg.mil/nmc/mmic_deckexquest.asp Have at 'em.
Seriously, we are trying to do this, and we have been sending groups of questions out tosegments of the industry to review and improve the questions. This includes the towing questions, but the only significant contributors from the towing industry have all been from Northeast operators.

<div>James D. Cavo</div>
<div>USCG National Maritime Center</div>
<div>Chief, Mariner Training & Assessment Division</div>
<div>James.D.Cavo@uscg.mil</div>

**captjacksparrow** · December 12th, 2008, 02:08 AM

I'm very well aware that the Coast Guard had to make a "no liability" promise to potential DE's back when the regulations were finally implemented in 2001. There were numerous objections from mariners about it and so they said it would be just like it is for flight instructors with the FAA: you're only attesting to the fact that you witnessed Trainee X perform this or that evolution satisfactorily within the specified standards on such and such a date and time, and no warranty against future incompetence, negligence or misconduct is implied or expressed, blah, blah, blah, etc. But the aviation sector doesn't have an equivalent to the 30-Day Wonder loophole, so making a straight comparison isn't very accurate anyway. And I think that the Coast Guard's promise isn't one that they could keep, even if I assume that they wanted to in the first place.
I'm also aware that there would be little risk of legal exposure to criminal charges unless the TOAR was fraudulently signed off. That doesn't concern me. What concerns me is the potential exposure of any DE to a civil lawsuit, where the standard is simply a preponderence of the evidence, not guilt beyond reasonable doubt, as in a criminal proceeding. The plaintiffs only have to score a 51% to 49% win in convincing a jury, and that jury is unlikely to be composed of experienced mariners who will understand our compromised position. Bad decisions by juries happen every day and I don't think that we're nearly as well-protected as you seem to think we are. When a good lawyer got done waving some DE's certification around in front of that jury and read to them what the Coast Guard's expectaions for DE's were you would have a tough time defending yourself. I know that those kinds of major accidents don't happen all the time, but they do periodically happen. And when the first one involving a 30-Day Wonder does happen I think it will get everyone's attention, big time, especially the DE's amongst us.
Time will tell, I suppose. It may take a while before the 30-Day Wonders burrow into the system and are in a position to wreak their damage, but I'm just not that optimistic that the DE's will be able to stave them all off. Quality control over the DE's themselves is highly questionable, and the 30-Day Wonder ruling gives the bad operators even more leverage on the honest DE's to hurry things up to suit them. Mercenary DE's for hire are sure to emerge sooner or later, if they haven't already, as the demand for their services rises. How many of us truly understand the magnitude of AWO's win? What they got their hands on are a huge pool of around 20,000 <100GRT licensed masters. Even with the bullshit "3 years of experience" requirement we're talking about a large number of licenses. They knew exactly what they were doing. When the next major accident occurs and the resulting new regulations are being dumped on us the politicians won't care in which particular CG District the accident occurred in, they'll just want the problem fixed, so the regulations will affect all of us, everywhere. I've been around long enough now to see this process repeat itself over and again. The only comfort I take out of this mess is the knowledge that both AWO and the CG will, sooner or later, regret their "victory" when the inevitable accident is splashed all over the news and Congress starts asking hard questions and looking for blood because of public outrage. But it's a damn cold comfort.
Mr. Cavo, I will certainly be glad to have a look at the question database and do what I can to help improve it. I'll also try to farm some of it out to my colleagues within the MTVA as well. But I feel compelled to point out the fact that we'd all have a lot more time to devote to this important and worthy task if we weren't having to spend so much of our time and energy trying to fend off the AWO's reckless 30-Day Wonder nonsense and their enablers within the Coast Guard, or plan how to prevent the upcoming inspection regulations from becoming a fiasco. As you know, unlike AWO, we don't have full-time lobbyists in DC working the Hill and CG HQ for all they're worth with their pie charts and powerpoint presentations. But we'll try to do the best we can anyway.....

**jdcavo** · December 12th, 2008, 05:04 AM

I'm not aware of any promise of "no liability" to Designated Examiners. I recall being asked to draft one about STCW assessments in around 1999 due to my past life as a lawyer. I siad I couldn't do it citing the legal ethics prohibitions on giving legal advice to someone who is not a client. Coast Guard lawyers agreed, and no promise was made for STCW. I''m not aware of and doubt it was any different for the TOAR.
In addition, as I'd previously posted, the STCW assessments were originally envisoned to be general and using a Coast Guard approved Designated Exanminer. Liability concerns expressed through MERPAC prompted a change to the numerous, very detailed assessments on the basis that the assessor was only attesting to witnessing a specific act at a specific time and it would be the Coast Guard making the conclusion of competence.
The TOAR is different. The tasks are general, and must be done by a Designated Examiner. As yours and every other Designated Examiner's approval states [emphasis added]:
<p class="MsoNormal" style="margin: 0in 0in 6pt 40px]<span style="color: #333399]<span style="font-size: x-small]<span style="font-family: "luxi-sans-1"]As mariners must now demonstrate their competency in a host of areas to obtain a license or endorsement for service on towing vessels, and eventually a Coast Guard license or document, the U. S. Coast Guard is placing a great deal of trust in your professional competence, judgment, veracity, and behavior. <span style="font-size: 11pt; font-family: "luxi-sans-1"]<o

></o

>
<p class="MsoNormal" style="margin: 0in 0in 6pt 40px]<span style="color: #333399]<span style="font-size: x-small]<span style="font-family: "luxi-sans-1"]In performing your function as a designated examiner, you may only use your signature or initials to indicate you have personally witnessed the demonstration of a skill or ability by the person being assessed and have found that individual, inThis letter will be revoked if you sign or initial a statement attesting to an individual’s competence without having personally witnessed a practical demonstration of the individual’s skill or ability, which in 
<p class="MsoNormal" style="margin-top: 0in; margin-bottom: 6pt; margin-right: 0in]<span style="font-size: x-small]
<p class="MsoNormal" style="margin-top: 0in; margin-bottom: 6pt; margin-right: 0in]<span style="font-size: x-small]<span style="font-family: "luxi-sans-1"]If you want to work on exam questions, contact me and I'll get you a set of our towing questions to work on. One of the issues the northeast group pointed out was differences in terminology on east and west coasts. Input from the west coast would be helpful.

Addendum: I've gotten several offers to assist in reviewing questions. I will accept these offers, and welcome more, and not just for towing questions. Thanks.

<div>James D. Cavo</div>
<div>USCG National Maritime Center</div>
<div>Chief, Mariner Training & Assessment Division</div>
<div></div>

**captjacksparrow** · December 12th, 2008, 11:57 AM

I'm certainly no lawyer, but I can read and comprehend the English lanquage fluently, and I think you just made my case for me, Mr. Cavo.
My reference to a "no liability" promise from the Coast Guard was referring strictly to various unofficial and unwritten assurances that I distinctly recall being made at that time to calm down the potential-DE's who were worried that they might be held responsible for someone else's misconduct or negligence at a later date. Had this not been addressed then a mass refusal to participate by the DE's-to-be might have torpedoed the whole thing, and it still could if a DE winds up in the hot seat without it being an obvious case of fraud or graft. Time will tell. Again, my main concern is our exposure to civil liability and comes from the fact that in time of need the marginal operators will apply potentially unbearable pressure on their DE's to sign off when they should not. And because DE's have to put food on the table and keep a roof over their heads it would be pretty naive to think that they'll always be in a position to "just say no" to their employer and/or quit their jobs. How about issuing the companies an operating license that could be revoked if they were caught deliberately gaming the system or pressuring a DE? Then you might have something. Right now it's all on the DE's.
This letter will be revoked if you sign or initial a statement attesting to an individual’s competence without having personally witnessed a practical demonstration of the individual’s skill or ability, which in your professional judgment, meets an acceptable level of performance.
So, anchorman and Capt. Pine, after reading the above statement (that is on my letter and should be on everyone else's as well) do you still think that a civil case jury would let the DE off the hook so easily after a major spill or loss-of-life incident? I'm not betting on it. The only thing that would make me trust the system to any degree would be specific wording in the letter that indicated that I'm simply an observer and grader of a "road test" while acting on behalf of the Coast Guard and, assuming that the assessment rules were followed, that the ultimate responsibility for an individual's negligent actions or omissions lies with them and possibly their employer.
Why do I feel so strongly about this? I move oil for a living, which is already risky enough as it is. I'm not in the business of providing legal warranties for other people. That's what insurance companies are for.
And Mr.Cavo, it's the very lack of specifics that makes the Maneuvering section of the current TOAR so lame. If the "industry" chose this then that is unfortunate. Laziness and resistance to change would be my best guess. Perhaps the PMI TOAR will eventually be recognized as the superior product that it is and be widely adopted.
I will be contacting you for those questions. Although I too work in the Northeast, many of my fellow MTVA members are on the Left Coast and I have contacts elsewhere around the country. We should be able to get their input, although the differences (outside of the Western Rivers) are generally minor I think.

**dougpine** · December 12th, 2008, 08:18 PM

Very interesting, and also troubling. It runs counter to what I was told when being trained as a DE, and what I have been passing along while training DEs. I'll be thinking twice before I sign off any more TOARs, and will also be revising the training materials to reflect this liability issue. I'm not interested in sitting at the green felt table, and I'm certainly not interested in being held liable for someone I've signed off.

**anchorman** · December 13th, 2008, 01:07 AM

The liability is clearly defined as witnessing practical demostrations (when you are present), hence the word"witness". There is no way possible, within the world of reason, where a DE can be held liable for another person's actions after signing off a TOAR unless the DE never witnessed a practical demostration, but signed off for it. End of discussion plain and simple. Debate is fine, but correlating perception to the real-world might prove troublesome, even in a court of law as far as liability is conserned. Does the Department of Motors Vehicles get sued everytime someone gets in a wreck? I'm sure they issued the at-fault driver a license. Show me one case.
Sparrow clearly doesn't like the 30 day rule, but when criticizing my post, Sparrow didn't even ask why or how I have signed people off as I have done, but instead questioned my professionalism and attitude, and the Coast Guard's. It might break his heart when he realizes that some of the best and most expericened guys around on a towing vessel are those on the large anchor boats,the ones that tow the oil rigs through oil fields and catch them during hurricanes, and most do not have or require to have a Master of Towing license. Most of these guys forgot more about towing than Sparrow can show them in 30 months; These same guys exemplify exactly why the Coast Guard has allowed and will continue to allow a 30 day rule.

**captjacksparrow** · December 13th, 2008, 10:38 AM

Sorry I offended you, Anchorman. I did not and do not question your professionalism one bit, but I most certainly do question the attitude you display here. I've worked in the oil patch and I know full well that the level of seamanship skills required for rig towing and anchor handling is very, very high. I also know that, because of this, many anchor boat captains tend to feel that everyone and everything else is beneath them, and not worthy of serious consideration. But we're talking apples and oranges here.
You haven't persuaded me and my view remains that the liability of DE's is not clear at all. You've got your opinion and I've got mine. Eventually it may well be decided in a court room, with the involved DE simply being a pawn on the receiving end of collateral damage in the bigger money game that is our legal system. I hope that other DE's at least consider the possibility of what they might be opening themselves up to.
Getting to the more important issue, you're right, I don't like the 30-day loophole one bit. Neither do any of the over 100 towing vessel masters who are fellow members of the Master of Towing Vessels Association. I suppose we're all full of shit, anchorman. Thanks so much for setting us straight on this. I also don't think that the status of being an anchor boat captain should entitle a DE to sign people off to be towing vessel officers without restriction when what you do is in many ways quite different from what the rest of us do. When I have questions about tractor tug ship-assist operations I talk with people I know that do it for a living, I don't call up my buddy who moves stone tows on the Hudson River. What makes anchor boat captains such experts on all things towing?
You may find this hard to believe, but when we were actively opposing the extension of the loophole this year I actually promoted the idea that an exception can and should be made for oilfield mariners with relevant experience. But definitely not in just 30 days. I offered a suggestion of 90 to 120 days as a compromise that received no consideration at all. Maybe you never saw or read the original towing vessel license NPRM, the interim rules, and the final rule from 2001 when they were published in the Federal Register. It's easy to see that the Coast Guard's decision to create the 30-day loophole for the >200 GRT licenses was just an arbitrary political decision made to appease people with big licenses and no towing experience or ability, and that's a fact. The argument for extending the loophole was based almost entirely on the basis that since 30 days was what the existing standard was meant that it would be fine to extend that loophole using that same standard. Our argument was that the initial standard was too low to begin with. There was never any informed debate on what would be a suitable amount of time, then or now.
As to why and how you sign people off so quickly, well, in the end that's up to you as a DE. If you want to enlighten us as to how and why you do it that way, please feel free. I sincerely hope that it never bites you in the ass.
And if you really believe that expanding a loophole that could be used for allowing dinner boat drivers to become towing vessel officers in as little as 30 days is a good idea then I'll continue to question your judgment, just as I'll continue to question the judgment of people in AWO and the CG who've never run a tug in their life making decisions on professional qualifications standards that they're clearly not qualified to make and directly affect our safety on the water.

**anchorman** · December 13th, 2008, 03:06 PM

Sparrow,
If we're talking apples and oranges, and you're not willing to see things in context, by stipulating we're talking about two different things, then there is nothing to talk about. I'm not trying to convince anyone of anything, I'm only trying to put into context what I have done as you decided to engage me on how I done it. I seriously doubt that I could enlighten you as requested. Since you already know how people tend to "feel", as a group, you must be the most enlightened of them all.
Who said anything about expanding a loophole by the way? Making a presumption about how I believe, then arguing against it, is akin to talking to a wall. I don't talk to people that talk to walls. What's the point?

**captmike** · December 14th, 2008, 12:49 AM

The pros and cons (mostly cons) have obviously been debated. I'm not here to do that. As a 1600 ton Captain that is trying to get his TOAR signed off, and after having read the debates, I have to believe that as DE's you have the judgement and experience to make the call whether or not to sign off a particular task. As Professional Mariners we are required to make judgement calls on a regular basis. Our jobs, livelihood, and lives depend upon it.
Whether we agree or not, the rules are the rules and until we affect change we must live by those rules.
I applaud CJS's enthusiasm and energy in trying to right something he believes is inherently wrong; however, I applaud those more that understand the system may be flawed but are doing what they can to continue to move forward and figure out a way to work thru the issue while still living up to the "spirit" of the law, avoiding available shortcuts provided by "loopholes".
If a candidate shows proficiency at a certain task, sign him off, no matter how long he has been "training". If he can't, don't sign him off.
I am also a PADI Scuba Instructor and their whole training regimen is based on proficiency. The student has a minimum required number of training dives to complete and a certain set of tasks that must be performed. If they can perform the task on the first try, then that is good. There is no maximum number of dives set, the students keep at it until they either complete the task or don't get certified. We, as instructors, are not liable for their competence in the future.

**captjacksparrow** · December 14th, 2008, 11:24 AM

The problem is, Capt Mike, that as long as that 30-day loophole exists there will always be the potential for a company that wants someone signed off quickly to put pressure on a DE to do it, and that the DE may then face some level of personal civil liability if and when that individual is involved in a disaster. We can't really know all the particulars until it happens, but the likelihood is that it will happen at some point. The regulatory shit-storm that will follow it will not be pleasant for us.
It also undermines the whole point of having the TOAR's, which came to be solely because safety imrovements were badly needed and letting everyone just wing it had proven to be a bad way of doing it. This current situation is not something that can be worked through with an expectation of long-term success, and wishful thinking won't change it. It must be gotten rid of altogether which requires that people must act.
We know that 30-day sign-offs are not the norm now, nor are they ever likely to become the norm. But they will happen, and probably already have happened. This is a matter of awareness on all sides: we want every DE to know that this is now the "law of the land", at least until such time as we may manage to get it repealed after the inevitable high-profile accident, and that in the meantime they should do everything possible to avoid it and to be prepared for its consequences. We also want people such as yourself (who are in-training) as well as those to follow to know that, despite the regulation, there should be no expectation that this loophole should ever be utilized.
Obviously, there are people that disagree with us. But every Towing Vessel DE I know or who has contacted us is absolutely appalled that this was ever allowed to happen, let alone that it was done with the active approval and assistance of the CG. Many verbal assurances were made, both from AWO and the CG, that it is "unlikely" and "unrealistic" that anyone could or would be signed off in that short of a period. That begs the most obvious question: if all the concerned parties agree on that point (that it is unlikely and unrealistic), and no one will actually do it, then why was it asked for and lobbied so hard for in the first place? An even bigger question is why is our country's primary maritime safety agency in the business of writing regulations that allow qualification practices that they themselves admit are unrealistic and not likely to be followed, but nonetheless allowed by regulation? Is that what anyone could remotely call promoting best practices within our industry? The members of the Master of Towing Vessels Association don't believe that the USCG should be in that business, nor do we believe that it is an unreasonable expectation.
We can't always just work with something that we know is really bad. Sometimes you have no choice but to fight it any way you can.
All of the DE's I know make it a personal policy to not sign someone off on a maneuvering objective until it has been performed multiple times under a wide variety of conditions. This may mean well in excess of a dozen times, depending on the individual. The bare minimum number of times a trainee should succesfully be able perform a maneuver to be considered "proficient" at it, however, is not defined in any regulation or in a CG NVIC or policy letter. It is elastic and subject only to the individual DE's determination, or perhaps that of their employer. It could be just 1 time, or 6, or 10, or 15, but no official guidance is offered one way or the other. You stated that "If a candidate shows proficiency at a certain task, sign him off, no matter how long he has been "training". If he can't, don't sign him off." Can you clarify what your definition of proficiency is? Some people think that a TOAR should be like a standard vehicle road test, rather than a long-term training process that actually may ensure true proficiency. Should a one-time succesful demonstration of a given maneuver warrant signing off on someone? Remember, we're talking about the movement of red-flag barges here, not a PADI or NAUI certification for recreational diving. If their dive certifications have a set minimum then why shouldn't a TOAR?
In any case, if you do make the cut and manage to stick in the wheelhouse of tugs, I would be very interested in hearing your perspective on this several years from now, especially if you become a T/V DE. In the meantime, I personally wish you the best of luck. It's not an easy path, but then it's not supposed to be.....

**mike173** · December 14th, 2008, 02:08 PM

No one's definition of proficiency is the same. Fair enough, but no one's level of proficiency is equal. If this were not the case, no black belt could ever beat another, and every doctor would be a brain surgeon and have the exact same skills. Obviously, this is not the case. Let's face it, what we do isn't exactly rocket science. While the TOAR is a good idea, it's just on example in a long history of the Coast Guard's grossly ineffective management of an industry they really know very little about. The Coast Guard repeatedly bows to industry wishes, while ignoring those at sea. Think about work hours, 2-watch system, reduced manning, and even the uninspected towing vessels. All fine examples of the USCG ignoring safety for the sake of industry profit. So maybe the "30-day rule" is a bad idea. What about an unlimited 2nd Mate being allowed to sit for a 1600 Masters License. Is a 23 year-old with one years sea time ready to command? Of course not. But the Coast Guard says he is. I've always lived by the idea that a license only authorizes an individual to work, it doesn't qualify him. Only experience can do that. And that experience is best gained when no one is around to sign you off, or back you up.

**captjacksparrow** · December 14th, 2008, 02:44 PM

You make some excellent points, and I agree with most of them. But we're not concerned with how proficient someone way be on the high end of the scale. It's the low end getting lower that worries us. On the proficiency scale the sky's the limit (multiple degrees of black belt), but there should still be a floor beneath which no one should be allowed to legally go (the brown belt) if they want to be a black belt. A+ through D- are all passing grades, but an F (or an F-!) is not. Inevitably, you have to draw a line somewhere, even if it can never be perfect in all situations. We have a ways to go on this.
The problem with the TOAR, I think, is more a problem of execution than anything else. It could be more useful to us and be done much better than it presently is, if people were willing to make the effort.
The Coast Guard's handling of this whole thing speaks for itself. And you're right, a person could get into a lot of trouble with a 1,600 GRT Master's license. I have also heard (2 or 3 years ago) that one or more of the 4-year schools (I don't know which ones) had sought and managed to get Coast Guard-approval for 1,600 GRT Master authority to go with the 3rd Mate-Unlimited licenses their graduates receive. I was never able to confirm this one way or the other, so it may just have been an erroneous rumour. However, I wouldn't be the least bit surprised it is, in fact, true. That's pretty sad.

**Capt_Anonymous** · December 14th, 2008, 03:46 PM

The 3m license carries 100 ton master authority, but I've never heard of them granting 1600 ton with that one. You have to be a 2m to get a 1600 ton Master.

**anchorman** · December 14th, 2008, 04:30 PM

....and soon to be Chief Mate before crossing over to 1600 ton Master. As per Jim, The full force of STCW will require Management Level STCW Classes.

**jdcavo** · December 14th, 2008, 04:36 PM

There are no Coast Guard approved programs for Master 1600 GRT. 
SUNY Maritime College and Maine Maritime Academuy have 500/1600 GRT undergraduate programs, they are separate from the 3rd Mate programs.
<div>James D. Cavo</div>
<div>USCG National Maritime Center</div>
<div>Chief, Mariner Training & Assessment Division</div>
<div>James.D.Cavo@uscg.mil</div>

**captjacksparrow** · December 14th, 2008, 11:45 PM

Those programs I knew about. Maine Maritime calls its 2-year Associate's Degree program Small Vessel Operations and SUNY calls it Marine Technology: Small Vessel Operation.
The 100 GRT Master authority with the 3rd Mate-Unlimited has been that way for as far back as I can remember. Whether that's a good idea or not is subject to debate. I've seen with my own eyes the impressive results of big, fast crew / suppliers being wrapped around wellheads in the Gulf by people that got their 100-ton license while working as a deckhand on a party boat out of Panama City. Our whole limited-tonnage system is really just a big joke. The licenses should probably be based on the displacement tonnage system, which seems to me to be a much more accurate reflection of the true size of a vessel than phony interior volume measurements and the associated exemptions. Crewboats approaching 200 feet and still under 100 tons? Come on.....
The unconfirmable story I had heard was that a school or schools, in an attempt to make attending said schools more attractive to potential students with lots of ambition and no sense, had somehow managed to get the 1,600 GRT Master tacked onto the 3rd Mate - Unlimited via creative use of curriculum and sea-mester underway time. I'm relieved to hear that this is not true, and I hope that this information is correct. Is it possible that it was sought and denied?
Another report I received this past summer, which came from credible sources presently working within the industry in the Northeast, was that some recent graduates of 4-year schools who lacked a towing endorsement and had minimal experience on towing vessels were able to get a TOAR completed in 3 or 4 weekends from a 4-year school in the Northeast and have been thereafter working (dangerously, I am told) as mates doing ship assist work. If this is, in fact, happening it should not be.

**captmike** · December 15th, 2008, 12:47 AM

CJS,
To answer your question regarding proficiency; that definition is at the discretion of the DE, a judgement call.
With respect to a recreational dive certification; the risk of permenant injury or death is very prevalent if certain standards are not followed.
It sounds like we all agree that the spirit of the law says that having a TOAR makes someone eligible to hold the watch, it does attest to their ability. Even if you have been running a boat for 30 years, when you go to another company or even another boat, you typically will be evaluated as to your level of competency.
WIth regard to to DE's being pressured to sign folks off by their employer; if you have any level of integrity, the company probably knows this and won't probably even ask. They will ask the ones that they know will succumb to their wishes. I don't believe we will ever rid the industry of those inviduals, the best we can hope to do is do our part to maintain our own integrity and do what we can to try to improve the areas we believe are flawed.

**captjacksparrow** · December 15th, 2008, 02:29 AM

Merriam-Webster Online defines proficient as "well advanced in an art, occupation, or branch of knowledge" and proficiency as "advancement in knowledge or skill" and "the quality or state of being proficient." It seems that until there is an accepted consensus as to what these terms mean in direct relation to the TOAR then there will be no resolution. If a TOAR isn't meant to be used to determine if someone is qualified to engage in towing operations then the Coast Guard should explain what it is for and why we're doing it.
In my experience, within a given towing company, it is not the norm that you would be formally re-evaluated as to your level of competency because you changed vessels. If you went from a small harbor tug to a large ATB, maybe. Or vice-versa if you've never worked a harbor tug before. Otherwise we are expected to be able to, and do, jump from boat to boat and cover the fluctuating personnel needs of the company. Changing companies may or may not result in a re-evaluation. It depends on both your background and the company, as well as how badly in need of personnel the company is. I can say with certainty that there are companies that will "hand you the keys" with little or no oversight if their need is great, just as there are companies that will carefully evaluate you and expect you to submit to a re-evaluation without being a crybaby about it. Standards vary widely.
It is understood that a personal failure while diving may result in serious injury or death. But compare the difference between someone who screws up on a dive and someone who screws up with a tug and tow. If you're a diver, chances are that you will probably only get yourself killed, or at worst take someone else with you who's attempting a rescue. The likelihood of a mass fatality is very, very low. The two individuals who between them knocked down the Queen Isabella Causeway in Port Isabel, Tx. and struck the RR bridge in Bayou Canot, Al. (Amtrak's Sunset Limited then derailed) killed several dozens. While the principles may be related the consequences are not even remotely comparable. The potential loss of life, damage to the infrastructure and environment, and financial impacts to commerce and individuals is enormous from a "bad day" on a tug. Look at the bill just for the most recent spill in NOLA.....

Thread: The TOAR: what's it for?

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