Tugboat Licensing Tonnage: Tons Of Misunderstanding

Due to the large number and specific nature of  internet searches that have lead net-surfing mariners to our website, it’s time to attempt an understandable explanation of the tonnage limitations for the towing licenses. The regulations are quite convoluted and confusing, thus leading to further mariner and management confusion, which in turn can lead to unintentional violations of the regulations. Maybe this will help a little.

Everything depends primarily on the route upon which the vessel actually serves. A license as Apprentice Mate, Mate or Master of Towing Vessels (endorsed for either Near Coastal or Oceans routes) entitles the holder to serve aboard towing vessels of less than 200 gross register tons (GRT), as measured by the U.S. domestic tonnage system, engaged in either near coastal (up to 200 nautical miles from shore) or oceans (beyond 200 nautical miles from shore) voyages. Ours is a ridiculous measurement system, in and of itself, but it’s the one we’ve got for now and that’s a subject for another post. In any case, the maximum tonnage of any towing vessel that can be operated upon Near Coastal or Oceans routes (with the Near Coastal or Oceans towing licenses) is 199.99 GRT, period.

What about towing vessels of 200 GRT and greater operating upon Near Coastal or Oceans routes? To operate them you must have an inspected vessel license of sufficient tonnage to cover the specific vessel (500 GRT, 1,600 GRT or unlimited) along with a towing vessel endorsement on the license or a completed Towing Officers Assessment Record (TOAR) signed by a CG-qualified towing vessel designated examiner (T/V DE). This is a simple either/or equation: if you have the completed TOAR in your possession you don’t need the endorsement on your license and if you have the endorsement on your license then you don’t have to carry around a completed TOAR. ¿Comprénde?

Once you shift to the Great Lakes, Inland and Western Rivers routes the picture changes significantly.  On these the Apprentice Mate/Steersman, Mate/Pilot and Master of Towing Vessels licenses have no tonnage limitation. How can this be? You may have noticed that none of the towing vessel licenses (regardless of which route is endorsed upon them) indicate a tonnage restriction. That’s because, strictly speaking, our domestic regulations don’t and never did call for one.

So if there isn’t a tonnage restriction printed on the license and it doesn’t call for one in the domestic regulations then why the 200 GRT limit for towing vessels operating on Near Coastal/Oceans routes and not for Great Lakes/Inland/Western Rivers routes?

The law that the Near Coastal/Oceans route tonnage limit is derived from, called the Officers Competency Certificates Convention of 1936 (aka the Officers Competency Act), is located in the U.S. Code at 46 USC § 8304, while the implementing regulations are at 46 CFR § 15.701. It stipulates that  “A person may not engage or employ an individual to serve as, and an individual may not serve as, a master, mate, or engineer on a vessel to which this section applies, if the individual does not have a license issued under section 7101 of this title authorizing service in the capacity in which the individual is to be engaged or employed.” With a few exceptions, this section applies to all documented vessels of 200GRT or greater operating on the high seas, including towing vessels. In this case the High Seas are defined as waters seaward of the Boundary Lines, which are, as per 46 CFR § 7.5(c), “lines drawn following the general trend of the seaward, highwater shorelines across entrances to small bays, rivers and inlets.” The exact location of all boundary lines can be found in 46 CFR § 7.10 through 7.180. As it happens, our towing licenses are not issued under section 7101 of Title 46 of the United States Code. So if you want to operate a towing vessel of 200GRT and up on the high seas then you must have a license that is issued under section 7101, which are the 500/1,600GRT and unlimited tonnage licenses. Simple, eh?

So the commonly expressed misconception that there’s some magical 300GRT towing license has no basis in regulatory fact. If you have a towing license, and only a towing license, then on near coastal or oceans voyages you are restricted to vessels of less than 200GRT. On any of the other routes there is no tonnage limit.

In the end it’s pretty cut and dried, but the regulations could damn sure use a major rewrite and reorganization so that we could find and understand all the relevant parts without spending hours sifting through the U.S. Code, CFR’s, NVIC’s, CG policy letters and so on. What a pain in the ass!