3 watch rule

[Azimuth]

I am trying to determine the requirement for establishing a 3 watch rotation on a voyage greater than 600nm. There is a clause in 46 CFR 15.705 that states "The Coast Guard interprets this, in conjunction with other provisions of the law, to permit licensed masters or mates (pilots) serving as operators of towing vessels that are not subject to the provisions of the Officers’ Competency Certificates Convention, 1936, to be divided into two watches regardless of the length of the voyage."

How can I determine if we are subject to the Officers’ Competency Certificates Convention, 1936?

[captbbrucato]

I'm not certain but I believe it has to do with operating outside the Demarcation Lines. If you don't cross the line the rule doesn't apply....
Here's a link to the Regulation... http://uscode.house.gov/download/pls/46C83.txt
From Joel Milton's research
http://towmasters.files.wordpress.co...tchkeeping.pdf
And some more reading
http://asvts.com/home/news/news_docs/utvreq.pdf

[Azimuth]

So if I read it correctly, 46 CFR 15.705d states than towing vessels of less than 200GT are allowed a 2 watch system regardless of length of voyage (and regardless of area of operation). Thanks for the link to the policy letter. I guess the good news is we won't have to hot rack!