With industrial Sunset Park in the background, the Buchanan 1…

…comes out of Erie Basin Cut with a loaded stone scow…

…and is immediately hit hard from the port side by the strong flood coming up the bay…

…which sets them up over the top of the Bay Ridge Anchorage as they head across to New Jersey.

Red Hook’s pre-Civil War brick warehouse waterfront, at the foot of Van Brunt St., and the just-for-show cranes of the old Todd Shipyard (now an Ikea), can be seen behind them. Forgotten NY has some interesting Red Hook observations and history, for all you urban archeology buffs  out there.

…

Well, it’s finally out! Yesterday the U.S. Coast Guard published their long-awaited Notice of Proposed Rulemaking (NPRM) for the Inspection of Towing Vessels, all 75 pages worth. The public comment period is somewhat better than expected: 4 months long, closing on December 9, 2011.

The sometimes-significant disparities in safety standards between towing vessels engaged in the exact same kind of work as inspected vessels and ships is long-standing and well known. Now, for the first time, it is also being publicly stated: “The Coast Guard notes Congressional interest in harmonizing requirements for oil tankers and vessels towing oil and hazardous materials in bulk.” They go on to say “The proposed rule meets this standard, by, in part, requiring alternative, independent methods of retaining propulsion, steering, and related control similar to those required of self-propelled tank vessels.” The wonders never cease! Now maybe we can finally put to rest the vicious circular reasoning that allowed this two-tiered system to exist for so long: Q. Why is it done this way? A. Because it’s a towing vessel! Q. How can towing vessels get away with this? A. Because they’re uninspected! Q. Why are they uninspected? A. Because they’re towing vessels! The time was already long past to do away with this mentality.

This belated recognition of the need for application of proper and comparable safety standards comes with a lengthy phase-in period: within 5 years of the issuance of a vessel’s first Certificate of Inspection (COI), which itself may take up to 4 years from the date that the Final Rule is published. Given that it will likely take at least a year for the Final Rule to become final, we’re looking at a full decade to completely implement this new system and make the necessary equipment upgrades to comply with it. This is very reasonable and there  should be no serious whining about it.

As expected, a Safety Management System (SMS), in this case to be called a Towing Safety Management System (TSMS), will be the cornerstone of the new inspection regime, and most of the mid-sized and large operators can be expected to go this route in one fashion or another. There are already examples, like this one from Tugboat Compliance Systems, Inc., on the market and we should expect to see more of them popping up like like mushrooms after a rain shower. A safety management system, however, will not be compulsory and may not even be desirable in some instances, especially for very small companies. Electing not to adopt an approved TSMS, an operator would instead “be subject to an alternative, annual Coast Guard inspection regime.”

Just in case anyone had doubts, I’ll spell it out for you: if an operator chooses to take the SMS-path the inspections are to be third-party with some Coast Guard oversight, and I don’t think there was ever any question that this was always how it was going to be. The massive size of the U.S. towing fleet means that the Coast Guard would need an enormous increase in marine safety personnel to do all of the inspections “in-house,” as is the case with other inspected vessels. With the American empire clearly starting to go into visible and unmistakable decline we simply do not and will not have the financial wherewithal to do it that way unless we re-think and change our current priorities, and there’s no sign of that happening at this time.

So third-party it is. We can only hope that the inspections that will result from the proposed system, as well as the oversight, are far better than those which utterly failed to correct the unsafe practices going on at DRD Towing. That systemic failure, wherein the auditing company regarded itself as “friends” with its “customer” (DRD Towing, the subject of the safety audit), directly contributed to and enabled the poor safety culture at DRD, which then led to the occurrence of the Mel Oliver fiasco on the Mississippi River in New Orleans. That accident, which occurred over 3 years ago, was investigated by the Coast Guard. For reasons unknown there has still been no public release of the completed investigation report, despite the fact that a co-owner of DRD Towing has already been sentenced to prison for obstruction of justice and his role in the accident.

Regardless of whether audits or inspections become dominant, the responsible majority of the industry needs to insist upon an honest system with the teeth required for enforcement. Otherwise it will just be a huge waste of time and money, with little or no serious improvements in safety. Furthermore, it will put the better operators at a competitive disadvantage to the corner-cutters, reducing the incentive for doing the right thing. That was clearly not the intent of Congress.

One of the most important areas needing major improvement is the reduction of mariner fatigue, which is to say manning and watch-schedules. The “traditional” 6 hours-on/6 hours-off schedule of the 2-watch system is, by definition, a direct cause of fatigue, but whether the Coast Guard will actually be able to do anything substantive about it if the industry digs in its heels against to maintain the status quo remains to be seen.

In their own words: “Without making a specific proposal at this time, the Coast Guard also seeks additional data, information and public comment on potential requirements for hours of service or crew endurance management for mariners aboard towing vessels. The Coast Guard would later request public comment on specific hours of service or crew endurance management regulatory text if it seeks to implement such requirements.” That’s still a very big “if.”

The industry as a whole could really step up to the plate, face this issue head on for the first time ever, and demand that everyone operate safely and on a level playing field by having adequate manning standards that are effectively enforced industry-wide. These new standards, to do any good, would have to treat humans as, well, humans, not automatons that can operate without quality rest. Whether or not the industry is collectively capable of this bold action also remains a big question mark. Time will tell.

The Coast Guard, however, minces no words in acknowledging the well-documented, dangerous and unhealthy effects of sleep deprivation. From FR page 49992, in the Sleep Loss and Its Consequences section, “Physiologically, at least two processes regulate sleep, one homeostatic and the other cyclic (also known as circadian) with a period of about 24 hours a day. The homeostatic process regulates energy availability and depends on the daily duration of sleep and of wakefulness; the need to sleep increases as wakefulness continues uninterrupted. The circadian process, also referred to as the body clock, regulates the time of the day when sleep is scheduled and also impacts the restoration and availability of cellular energy. In brief, the body clock abhors uncertainty; it prefers stable, daily sleep beginning at the same time(s). These studies show that both of these processes work well with daily sleep periods lasting at least 7 uninterrupted hours, where that sleep occurs at consistent times from day to day. Additionally, significant disruptions of the timing of daily sleep onset, or restriction of the duration of sleep below 7 uninterrupted hours per day, result in significant impacts on human physiology, health and performance.” There is no excuse for failing to act on this.

To comment go to federal docket USCG-2006-24412 (you’ll know you’re in the right place when you see NPRM: Inspection of Towing Vessels under the Document Details heading) and click the Submit a Comment button on the right-hand side. From there, after entering the required information in Section 1., you may type in your comments (up to 2,000 characters) in the box provided in Section 2. Alternatively, you may upload your comments, in the form of either Word (.doc) or Portable Document Format (.pdf) files, in Section 3.

Don’t be in a hurry to comment. Instead, take a deep breath and start reading. Think about what you’ve read, and then think some more, maybe lots more. Highlight stuff and make notes. Talk amongst your peers. When you’re ready, gather your notes and thoughts, then start writing. This is a pretty big deal in the history of this industry and it needs to be done right. To get it right, mariner input (as in working mariners) is essential. Think first, then participate.

You will be able to read any and all of the comments submitted to this docket as they are posted to the Docket Folder Summary. There are already a load of pertinent reports and studies there, so do some browsing on the subjects that interest you. You can even sign up for automatic notification whenever anything is added or modified on the docket. Just click the E-mail Alerts link just below and to the right of the Docket Folder Summary header near the top of the page.

Enjoy…

The Leslie Foss inbound at Deer Island Light on a steamy summer morning. This was the final leg of a long round trip: Boston to Milwaukee with a light barge, Milwaukee to Baie-Comeau with a crane, and back to Boston light-barge again. Below, the adventure begins…

Last year there was a meeting of the minds in Manila to hash out the latest major round of changes to the STCW Code, which are scheduled to “come into force” on January 1, 2012. That’s only five months away and counting down. Effective August 1st, the Coast Guard has published a Supplemental Notice of Proposed Rulemaking (SNPRM) for Implementation of the Amendments to the International Convention on Standards of Training, Certification & Watchkeeping for Seafarers, 1978, and Changes to Domestic Endorsements, which is an updated and expanded version of the original NPRM from last year. Make no mistake, there are lots of very significant changes to STCW contained in this revised document and it is important for individual mariners to read the SNPRM and comment on them well before they get to the Final Rule-stage of implementation.

In the medical category here are two big ones:

• Issuance of “medical endorsements” good for 1 year for 1st-class pilots and those “acting as pilot” (all towing vessel deck officers), 2 years for those serving under an STCW endorsement, and 5 years for all other mariners.
• The requirement for annually submitting the results of your physical to the Coast Guard (for 1st-class Pilots and those “acting as pilot”).

Pain in the rear or not, having to send the results in to the Coast Guard was long overdue since their performance of due diligence before some medically-related disaster occurs is almost impossible without it. We’ve already had two very serious incidents because of this problem. One in San Francisco Bay, a major pollution incident when the M/V Cosco Busan struck the Bay Bridge, and the other a ferry crash in New York Harbor that killed 11 people and injured 70 more. Lesson learned: we don’t need anymore of these. On the other hand the Coast Guard is still mis-handling the medical process, sometimes very badly, by a lack of transparency and an inability to give mariners clear and timely answers. This needs to change too, and mariners have grown inpatient and angry while waiting for a reasonable level of service to be attained.

There are also many proposed changes to our domestic system. For the towing vessel community, here are the changes to be found in the “domestic endorsements” area that are solely applicable to our sector.

• Create a towing vessel endorsement restricted to ATB’s, to be called Towing Vessels (ATB).
• Create a towing vessel endorsement restricted to ship-assist tugs, to be called Towing Vessels (Harbor Assist).
• Eliminate the requirement for formal Coast Guard-issued qualification as a Towing Vessel Designated Examiners (TVDE’s) to complete Towing Officer’s Assessment Records (TOAR’s). This change would “allow mariners to serve as DE’s by virtue of their endorsement without any further approval process.”
• Create a new sub-classification of towing vessel endorsement (Master and Apprentice Mate/Steersman) to be called Towing Vessels (Utility) for what had formerly been known as “assistance towing” for recreational vessels.

The first two new endorsements are positive changes that will help the present situation by standardizing the sensible practice of limiting tug operators who have no experience with conventional towing operations. A full TOAR simply cannot be completed aboard most typical ATB’s. It has long since become a practical impossibility (for both mariners and operating companies) for ATB personnel to get the required additional experience on conventional tugs for completion of the TOAR, just as the opportunities for that are rapidly dwindling in the petroleum trade. This had caused an unnecessary advancement bottle-neck, which was informally solved by Coast Guard acceptance of slightly-modified TOAR’s for ATB’s that were company-specific. Formalizing this existing practice is a good idea.

Getting rid of the need for DE’s, however, is not a good idea. Consistency and quality-control have been improved since the implementation of the TOAR system, and Coast Guard-certified DE’s are the backbone of it. Towing isn’t like anything else and requires more of a mariner, both the trainee and the trainer. We don’t want to go backwards on this.

The Towing Vessel (Utility) endorsement has the potential to improve and fully professionalize the assistance towing industry, and that deserves support. But there will need to be some very clear limits placed upon what constitutes utility towing, as in size/horsepower limits on the utility towing vessels and size/tonnage limits on what they may tow. At what point does it cross the line and become regular towing? Failure to do this will certainly lead to the same kind of abuse that has already been occurring for years: the long-standing practice of assistance-towers working well beyond the scope of their licenses. In the past and into the present, this took the form of towing things other than disabled vessels. With a significantly expanded range of work potentially being legally opened up to them, the former assistance towers will be much more able to bite off far more than they can chew, with all of the associated safety issues that entails. This bears watching.

What follows may be a big step in repairing their reputation amongst working mariners, as long as it’s done right.

• “The Coast Guard proposes to add a provision for issuance of a ceremonial license, which reflects his or her existing domestic officer endorsements, and is suitable for framing. The addition of this optional license is being proposed in response to numerous requests from the public.”

Well, not for nothing, but there were plenty of public comments in support of this before they did away with the traditional paper license. It never fails to amaze me how the Coast Guard sometimes blindly squanders whatever good will it manages to build up with mariners by doing things that disappoint and anger us. Especially when it was all easily avoidable. They could have heeded the advice they received beforehand and missed out on all the bad mojo. Oh well, better late than never. However, let me define “done right.” It has got to be way better than the cheesy digital-download facsimile that you had to print yourself, which were made available last year. We want the real deal, printed on high-quality paper, with the raised stamp and everything, just like we had before the Merchant Mariner Credential was created. It’s understood that this takes time and resources to do, so we’ll gladly pay a fair price for it. There was never any argument about that. This will pay long-term dividends in improved mariner relations and the Coast Guard would be foolish to allow another stumble here.

And here’s a little doozy that they tried to slip in while no one was paying attention:

• “Possible changes to fee payment options, as proposed in § 10.219, which would eliminate the possibility of paying by cash or check.”

This one should be dead-on-arrival, since it is clearly illegal, at least as far as cash is concerned. Printed upon the face of all denominations of our paper currency, on the left-hand side, are the words “THIS NOTE IS LEGAL TENDER FOR ALL DEBTS, PUBLIC AND PRIVATE.” Neither the Coast Guard, nor anyone else, has the legal right to refuse cash (in all forms) issued by the Federal Reserve on behalf of our own government. The Coast Guard can’t arbitrarily change by regulation what Congress has not changed by law. Regulations must not contradict the law, and there is nothing unreasonable or illegal (for the relatively few who still do it) in being able to walk into the nearest R.E.C. and pay for the transactions with the formerly-almighty greenback, shaky though it may be these days While there are certainly efficiencies gained by doing it electronically, the claim for a need of “specially trained personnel” to handle cash is, literally, a Whopper. Burger King, and every gas station and convenience store in the land, seems to be plenty capable of handling significant amounts of cash with minimally-qualified workers who are paid very little. Are we to believe that the U.S. Coast Guard just can’t handle it? They must be kidding. In any case they ‘ll almost certainly do it anyway because it’s highly unlikely that anyone will sue them over it, the only real legal remedy available when government agencies break the law. Unless Congress puts a stop to it! Right…

Anyway, further analysis will be forthcoming. As of right now the deadline for the submission of comments is September 30, 2011. When you’ve read it through and had time to think about it, click here (for Federal Docket USCG-2004-17914) so that you can let your opinions be known.

We were at the very top of the Liston Range (inbound for the ConocoPhillips refinery at Trainer, PA) when we met the massive ATB OSG Vision…

…which was outbound on another lightering run down to Big Stone Anchorage at the bottom of Delaware Bay. We were well out of the channel on the green (west) side and very gradually slowing down to pick up our barge alongside.

The sailboat you see astern of them in the first photo, however, was doing what sailboats (and many other pleasure craft) often do: navigating in a deep-draft channel when there is absolutely no compelling need for them to do so. In fact, there is a tendency to do it precisely and especially when and where there are very good reasons not to, such as when large ships, tugs with tows and other commercial vessels that must be in the channel because of their draft are in the vicinity. This one was more-or-less paying attention to the fact that they were in one of the busiest shipping lanes in the country and they did move out of the channel, though in a very leisurely manner. But many pay no mind at all until the horns start blowing 5+, and then they either play dumb/ignore you or else panic and begin maneuvering erratically. It’s surprising that despite the casual-at-best approach to good seamanship and navigation, the gross stupidity, the blatant ignorance, and the inattention to their own and other’s safety, very seldom do these boaters actually earn themselves a Darwin Award. It’s rock-solid proof that you can go a long, long way on fool’s luck.

It seems that many recreational boaters, as well as the Coast Guard, assume that we’ll always be able to (and should) compensate for the other’s ignorance, inability or dangerous obstinacy (“I have the right to be in the channel, too!”) . They should remember that without exception we’re just imperfect humans and, as such, we can have a bad day just like anyone else. Some among us are, to varying degrees, incompetent, as is the case with all professions. Regardless, the “Rule of Gross Tonnage” dictates that if we’re having a bad day and they’re having a bad day, resulting in both vessels attempting to occupy the same patch of water simultaneously, the small recreational vessel and its occupants will undoubtedly lose that contest. A good rule of thumb: drive defensively and always stay away from other vessels, any vessels at all, if there’s not a damned good reason to be near them. Distance buys you a greater margin of safety. Perhaps the Coast Guard is reflecting on some of this a little more deeply after their own small vessels have been involved in a pair of recent high-profile, back-to-back accidents (in Charleston, SC and San Diego, CA) which resulted in civilian injuries and deaths. Yes, it can happen to anyone.

Soon enough we were past each other, the sailboat sailed off, and we flopped around on our barge and made up to it . All was well, this time…

…but the sailboats don’t always surrender to not-so-common sense quite so easily.

There is, of course, a rule long since in place to “encourage” small vessels to refrain from being a navigational nuisance to others and a danger to themselves: specifically, section (b) of Rule 9 (the “Narrow Channels” rule) in the Collision Regulations. It reads “A vessel of less than 20 meters in length or a sailing vessel shall not impede the passage of a vessel which can safely navigate only within a narrow channel or fairway.” It sounds logical enough but there has always been a very serious flaw with it: namely that what constitutes a narrow channel or fairway has never been clearly defined. There are other flaws as well, but that is the big one. As it happens, a timely article titled Taking Narrow Channel Collision Prevention Seriously To More Effectively Manage Marine Transportation System Risk  by Craig H. Allen, published in the Journal of Maritime Law and Commerce, covers this subject in great breadth and depth, and it should be required reading for every mariner.

Here’s the money-quote from the paper: With shrewd understatement, two of the world’s leading authorities on the rules of the road for preventing vessel collisions report that “the term ‘narrow channel’ is not easily defined.” Indeed, the international conference that drafted the 1972 COLREGS rejected a proposal to to include a definition of “narrow channel” and the United States Congress simply ignored the matter. Perhaps, like “pornography,” another mixed question of law and fact, we should be content to know a narrow channel when we see one, even if the rule drafters cannot define it for us. Many believe that mariners – and those who depend on mariners to prevent accidents on the nation’s waterways – deserve better. The U.S National Transportation Safety Board (NTSB) agrees. In its investigation into a 1981 collision between two towboats, one of which concluded the inland rivers location fell within the narrow channel rule while the other concluded it did not, the Board reasoned that it does “operators little good to learn months after an accident that a court has ruled that a particular portion of a waterway, under a particular set of circumstances was or was not a ‘narrow channel’ under the rules, and that the narrow channel rule should or should not have been applied by the parties involved in the accident. Who could put it any better than that?

Thirty years later, here we are. To be fair, a “vessel which can safely navigate only within a narrow channel or fairway” will always be a relative term: relative to the ratio between the vessel’s draft and the actual depth of the channel, as well as the depths available outside of the channel. It may also vary with the changing tides, currents and weather. Nevertheless it is still possible to give the rule some practical and useful meaning for all mariners, which is something it has always lacked. In so doing it would also allow for useful instruction to be given to non-professional mariners so that they might also understand their rights and responsibilities better, and maybe a touch of common sense. Too many only hold a partial understanding of the navigation rules, and the parts they tend to know and recite are (surprise!) the parts that tell them that they have the right of way. Who among us hasn’t been subjected to the indignant rage of a weekend-warrior sailboat “captain” as they remind us that they, if only in their mind, have the right of way? Forgotten or, more likely, never learned in the first place are the parts of the rules that burden them with an equal portion of responsibility for safe navigation. The nuances of the rules, and the exceptions, escape them. For those of us engaged in the day-to-day grind of navigating around ignorant pleasure boaters and fellow “professionals” whose grasp of the rules is also lacking, it gets really old.

Ultimately, better education for everyone, and I mean EVERYONE, is the only answer that offers to improve the situation. But it’s hard to educate anyone when there is no solid base to start from, a definition or set of definitions that is agreed upon beforehand. There now seems to be some momentum building towards establishing such a base via the recently re-established (praise be!!!) Navigation Safety Advisory Council and through the explicit designation of narrow channels by the U.S. Coast Guard. This could not have come soon enough.

 I will make the following observation/recommendation: the length of a given vessel should, in most cases, be mostly immaterial for the purposes of applying this rule. The whole point of the rule is to avoid situations where those piloting large vessels in locations where their maneuverability is limited solely to the channel are faced with the lousy choice of possibly killing someone or going aground, which may entail serious and costly damage to the environment as well as injuries to personnel, damage to the vessel, loss of cargo, and other unforeseen consequences. It is generally the vessel’s draft that is the deciding practical factor and it should be the deciding legal factor as well. While there is often a direct correlation between a vessel’s length and it’s draft (longer usually means deeper), one does not always follow the other in linear fashion. In any given situation it ‘s possible that the smaller (in length) of two given vessels may, in fact, have an equal or deeper draft and thus have the same or even more limitations as to where it can navigate safely.

Furthermore, if a vessel’s draft allows it to be safely navigated outside of the channel when in the vicinity of vessel’s that need the channel then it should be. In the event of a collision (or a grounding of the channel-constrained vessel as a result of trying to avoid a collision) the burden should fall to the operator of said shallow-draft vessels to explain and justify their unnecessary presence in the channel. Having an arbitrary cut-off of 20 meters in length really doesn’t do anyone any good at all. A 20 meter vessel can impede ships in a channel but a 19.9 meter vessel can’t? This rule definitely needs a re-write.

The arguably narrow dredged channel up the Delaware Bay and River to Philadelphia is a great example. When we have a loaded tank barge (18’6″ maximum draft) there are areas where we need the channel, areas where we don’t, and areas that are questionable. Such is life! Assuming for 100% accuracy in the published charts, which may not always be a good bet, with our draft I’d say it’s about a 50/50 split. When the barge is light and the tug’s draft of 13’6″ is the deeper of the two then it shifts to maybe a 70/30 ratio in favor of being able to be outside the channel to some degree. My own general rule is that if the depths and maneuvering room are sufficient so that I don’t need the channel then I stay out of the channel and leave it to those that do need it.

Where’s me pot o’ gold? The Penn No. 4 ponders that eternal question while southbound off Inwood Hill on a warm and muggy mid-June evening.

A built-in-NY Connecticut Yankee: the 1952-vintage Bushey classic Towmaster…

…soaking up some late-day sun in New London, CT. Bearded tugs are getting farther and fewer between these days, so it’s nice to see a few of the old classics still hanging in there.

With the distinctive look of a Bollinger-built ex-Otto Candies tug, which it is, Hornbeck’s Eagle Service…

…tows the Energy 13502 on a short wire, southbound out of the North River and into the Upper Bay on their way out to sea.

The Candies tugs were originally built primarily for oil rig and lay barge towing in the Gulf oil fields: the trunk and the upper house were added on later for doing tank barge work, where seeing over the tow is necessary.

You know those decals you see on the larger delivery trucks and tractor-trailers that read “If You Can’t See Me I Can’t See You.”? Well, how about this small tug with a loaded “scrappy” (scrap-metal scow) power-sliding wide around the construction barges on the seawall at Corlears Hook with a max-ebb East River current on their tail…

Can’t see the operator, can you.

Nor can you see any sign of a lookout. This is a pretty flagrant foul, as these things go, and unfortunately it’s not at all uncommon. Keep in mind that this tug/scow combo was coming directly at us while digging hard to get back over to the Manhattan-side of the river. Once they got fully into their turn around the hook they were literally going sideways and therefore, because of the obstruction presented by their tow, unable to see where they were actually going or any oncoming traffic. In fact, they would have been looking directly at the Lower Manhattan shoreline and hoping like hell it all worked out. It was a Wile E. Coyote-style moment: arms and legs spinning wildly as he sails off the cliff edge…but in the end it did work out, which only reinforces the bad idea that it’s okay to keep doing it.

Apparently we can do things correctly and responsibly or we can do things profitably, but we simply cannot do both at the same time, or at least that’s the implication a reasonable person might take from seeing things like this. Of course, that is pure BS. You have to give credit where credit is due, though: they sure did one hell of a job loading that scow as full as possible, so someone was making money.

But why no lookout? That’s simple: either the tug’s crew is negligent (qualified personnel were available but unused) or the tug is under-manned. Under-manning (both practically and legally) is a chronic problem, particularly on the smaller tugs doing the “low-value” (non-oil) work, and this practice predates the economic woes that presently grip our country and the rest of the world. The Coast Guard has thus far shown little inclination/ability for any real, sustained enforcement of even the existing weak regulations which, among other shortcomings, place no explicit limit on the work hours of deckhands. Nor have they shown any taste for promoting the obvious remedy: recommending to Congress, via a legislative change proposal, a revision of the laws (U.S. Code) that the manning regulations (Code of Federal Regulations) are derived from. Which is not to say that Congress would necessarily heed that advice, or even want to hear it in the first place: there are, after all, some influential “constituents” out there who would undoubtedly complain that properly manning their vessels would put them out of business and so would argue (and lobby) forcefully against it.

Anyhoo, for a good visibility comparison here’s the tug Paul Andrew…

…whose skipper clearly can see over the tow, even without a designated lookout…

…because the upper pilothouse allows for it. Well, duh!

This tug, the Charles D. McAllister, with the car float alongside has enough height-of-eye to easily see over the box cars, even without an upper house, and would normally need the assistance of the deckhand’s eyes only when in close proximity to the slip and float bridge for sailing and landing.

This one is questionable…

…because of the blind spots created by the on-deck obstructions. If there is a lookout then they are well-hidden. The upper pilothouse would be a much better vantage point for the operator but then, as you can plainly see, carbon monoxide poisoning would be a distinct risk, along with the negative health effects (asthma, heart disease, lung cancer, etc.) of breathing in lots of concentrated particulate pollution from the diesel exhaust. But hey, there’s no need to protect the health of the people that work on these vessels because the vessels are uninspected! Oh wait, Congress ordered them to be inspected years ago. Whatever…

But sometimes there’s no way that you could ever have an upper pilothouse tall enough…

…to see even a little. One would hope that they have at least the basic deckhand lookout posted, and from my observations over the years that has usually been the case. But is that really enough?

Using an unlicensed seaman (no matter how experienced) to serve as the only set of eyes for a 180-degree or more blind spot would probably be viewed as legally-questionable at best if an accident occurred. This is an area that I’ve never seen addressed: at what point visibility-wise have you crossed the threshold between situations that require just a standard lookout (a properly trained and supervised ordinary or able seaman) and those situations where only a fully-qualified deck officer will do. If there is any sort of substantial obstruction of visibility or blind spots forward of the tug’s beam I think a very good argument can be made for requiring an additional deck officer capable of giving actual steering recommendations/commands to the officer conning the tug for the general purposes of collision avoidance and safe navigation. Having to rely on a basic lookout that can only give you bearings and ranges to other vessels, docks, buoys, and other hazards is a rather frightening position to be in when half your visibility is gone. You’re completely at the mercy of someone who, when it comes right down to it, probably doesn’t have the knowledge, experience, judgment and ability, and almost certainly not the legal standing, required to give you accurate and useful steering recommendations in close-quarters situations, when that might well be the only thing that can save you.

Below, for example, you see two personnel posted forward on the barge. Is one of them a senior, more-experienced AB-deckhand that might actually know the harbor (buoy system, channels, traffic patterns, hazards, currents, etc.) well enough that they could be of real use (very rare these days), or is the extra person an officer? If so, is that officer a temporary extra (carried aboard on this job just for this purpose) or was he the only other officer on board in a 2-watch system, woken up while off-watch (illegally) to do this? Who knows? Either way, it looks like they’re at least trying to do the right thing.

But I think it’s fair to say that if the average person saw trucks driving around in a similar fashion of severely obscured vision they would be very alarmed by it, and rightfully so: imagine a tractor rolling down the highway through traffic with its trailer “on the hip.” Trying to explain it away by saying “Well, that’s just the way we do it!” simply isn’t good enough.

Sometimes…

…container barges get towed across or through the harbor, but that brings a whole different set of potential problems with it, primarily related to controlling an unwieldy tow in confined waters with a lot of traffic and current, which is why it isn’t often done that way. Of course, if the boxes aren’t stacked too high in the first place…

…you can see over them with no problem at all. Even loaded to just one or two tiers high, that’s still a hell of a lot of tractor-trailers off the roads and bridges.

The bottom line is this: if the officers conning tugs can’t see over and around their tows, and don’t have adequate numbers of properly-qualified additional personnel in place to make up for that fact (and without violating the watch/work-hour limits), then the tug shouldn’t be engaged in that work, period. This is largely a manning problem. Failure to enforce realistic manning on towing vessels only diminishes the Coast Guard’s standing as a marine safety agency.

For further information please see the following highly-relevant reports from the National Mariners Association:

• R-207, Rev. 1: Training & Posting Lookouts
• R-275, Rev. 3: Navigation Bridge Visibility
• R-370, Rev. 3: Watchstanding & Hours-of-Service Limits Using The 2-Watch System

All of the other fine NMA Reports can be located here. There’s not much in the way of mariner’s issues that they haven’t covered at one time or another, so take a little time and read up on them. You might be surprised at what you don’t know.

The wedding cake at the “Swimming Pool”…

…tug Maryland running light boat eastbound in the KVK.