Towing License Sea Service Requirements

The important points are as follows:

 

1. The petition from Delta Towing of Galliano, La. (a subsidiary of Edison Chouest Offshore, a large oilfield vessel operator) was originally intended to solve their own problem of being short on qualified wheelhouse personnel for their tugs by being able to use experienced captains from their oilfield supply vessels and crewboats after they met the following conditions: pass the written exam for apprentice mate or attend an approved course, get a TOAR signed off, and complete 30 days of training and observation aboard a tug. Although they do mention in passing the potential added benefit to the industry-at-large of helping to reduce the overall manning shortages, it appears clear that they meant that this advancement path was to apply primarily to their own oilfield mariners. For those of you unaware of it, the oilfields are just as short, if not even shorter, on qualified mariners as we are. This is, for now at least, simply an in-house fix for Delta Towing. It won't help the rest of the towing industry any time soon, if ever. It would, however, set a very bad precedent.

 

2. I think that using experienced oilfield captains is an idea that has considerable merit. As I stated in my letter to the federal rulemaking docket, these are the kind of mariners that would have the least problem making the transition out of anyone I can think of. However, 30 days is just too short of a time frame, and no one is going to legitimately complete a TOAR in 30 days, period. I feel perfectly comfortable stating that it is flat-out impossible. I would, however, fully support a provision that limited this path to oilfield mariners with adequate experience, as long as the training and observation period was long enough. I proposed a minimum of 90-120 days in my letter to the docket, and even then I think I was being generous. That is the absolute lowest end of the range that I feel it would be possible to do it in without compromising safety unnecessarily.

 

3. American Waterways Operators (A.W.O.), the towing industry's lobbying organization, in their comments to the docket, went well beyond what Delta Towing proposed. They suggested that the Coast Guard also extend this path of advancement to <200 GRT Mates as well, and also that the proposed 3-years of experience on the license need not be served in a licensed capacity at all, or even on a towing vessel. This is foolishness of the highest order.

 

4. A.W.O. has claimed that this was endorsed by the Towing Safety Advisory Committee (TSAC), the implication being that TSAC as a whole is a real authority on marine towing safety issues and if they give it their stamp of approval then it must be okay. But the only working mariner on TSAC at the time this was being worked on, Capt. Joe Dady, was not a member of the TSAC working group that came up with this, nor did he vote for it. In fact, no actual working mariner has ever gone on the record to endorse this at all. Look at the comments on the docket. Two Coast Guard-certified Designated Examiners, among other mariners, have stated that it is a bad idea and will make our industry less safe.

 

5. The proposal as published by the Coast Guard, and endorsed by A.W.O., would not restrict this path of advancement to only experienced oilfield seamen. Rather, it would be open to any holder of a 200/150/100 GRT Master's license (AWO wants the mates included, too) with three years on the license, no matter how and where they got the sea time to qualify for that license in the first place, or how/where they got the proposed three years on the license to qualify for this advancement path. This would include operators of charter boats, commercial fishing vessels, small passenger vessels and ferries, excursion vessels, dinner boats, etc. In the vast majority of cases these people are completely unqualified to serve as anything but an apprentice mate for at least a few months, if not years. Creating a route by which these licensed captains and mates could be fast-tracked into the wheelhouse of a tug means that, sooner or later, one way or another, they will be. This will undoubtedly lead to accidents that would have otherwise been avoidable. Given the times, and the disposition of the public and Congress, another major accident attributed to our industry will very likely unleash even more training requirements and hardships that we don't need or want.

 

6. Since everyone agrees that no reputable company would hire and place in such a position of authority and responsibility a person with only 30 days experience on tugs, that leaves only the disreputable companies to do it. Without a doubt, a few will always do what they want anyway, regardless of the law, and hope they don't get caught at it and/or get in a huge accident causing multiple fatalities, especially innocent civilian fatalities, such as occurred in the I-40 bridge strike and collapse in Oklahoma. Such is life. But to prevent them from being able to legally get away with an unsafe practice the 30-day provision should be removed altogether and replaced with a much more realistic period of time, as I outlined in my comments to the docket.

 

6. To leave it at just 30 days would be, in essence, giving the Coast Guard's full endorsement to an obviously dangerous practice. I'll also add that the Coast Guard simply lacks the in-house, professional expertise to make a judgement call on something like this. TSAC should but doesn't, mostly due to the fact that working mariners are way under-represented on the committee and don't appear to be seriously listened to in any case. Since the Coast Guard relies on TSAC for the towing safety expertise they (the C.G.) don't have, and since TSAC appears to be unable to offer sound safety advice untainted by other agendas or the inexperience of its non-mariner members (the large majority), the Coast Guard is simply left with generally poor advice to work with. TSAC's members may mean well, at least most of the time, but they will never overcome this big shortcoming until working mariners become a majority whose advice is heeded. This is the root of the overall problem.

 

Joel Milton