The US Coast Guard issued a Policy Letter 19-01 ‘Enforcement Guidance for Harbour Assist Vessels When Operating Beyond the Boundary Line’ to provide information to towing vessels in regard to manning, credentialing, and watchkeeping requirements applicable to harbor assist vessels inspected under 46 CFR Subchapter M.
Specifically, vessels calling on US ports keep on increasing in size, technical complexity, and number, creating a more complex Marine Transportation System.
The towing vessels play an important role in the safe and efficient transit into port for vessels that have a limited maneuverability, and provide a safeguard in the event a vessel loses power or steering.
To facilitate effective waterways management while mitigating safety concerns, harbor assist towing vessels have been transiting further from the port to meet vessels, and may be required to cross the Boundary Line.
Concerning the boundaries, towing vessels inspected under Title 46 CFR Subchapter M receive a Certificate of Inspection that defines the routes and conditions a vessel may operate upon, along with manning and credentialing requirements.
The Officers in Charge and Marine Inspection (OCMI) make clear the minimum manning complement that is necessary for the safe operation of the vessel, in light of applicable laws, regulations, and all other factors involved such as size and type of the vessel, installed equipment, and proposed routes of operation.
Generally, the majority supports that the harbor assist towing vessel sector of the industry doesn’t meet the prescribed manning and credentialing requirements when temporarily operating outside the Boundary Line.
Therefore, to avoid disruption, this letter provides guidance for the OCMI to exercise discretion with enforcing regulations, related to manning schemes, credentialing, and watchkeeping requirements so that the relatively few towing vessels that conduct harbor assist operations outside the Boundary Line have additional time to develop a workforce and business model to achieve compliance.
The Coast Guard alerts that this letter is not a legal requirement. It represents the Coast Guard’s current thinking and might be a way to better assist industry, mariners, the general public, and the Coast Guard, as well as other Federal and state regulators, in applying statutory and regulatory requirements.
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