Commercial Vessel Compliance

4/8/2019: Policy Letter 19-01 – Enforcement guidance for harbor assist vessels when operating beyond the boundary line

The Office of Commercial Vessel Compliance published Policy Letter 19-01, “Enforcement Guidance for Harbor Assist Vessels When Operating Beyond the Boundary Line” to provide guidance to towing vessels regarding manning, credentialing, and watchkeeping requirements applicable to harbor assist vessels inspected under 46 CFR Subchapter M.

Vessels calling on U.S. ports continue to increase in size, technical complexity, and number, creating a more complex Marine Transportation System. Harbor assist towing vessels serve an integral role in facilitating a safe and efficient transit into port for vessels with 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, as a result, be required to cross the Boundary Line.

Towing vessels inspected under Title 46 CFR Subchapter M receive a Certificate of Inspection that clearly defines the routes and conditions a vessel may operate upon, along with manning and credentialing requirements. The OCMI specifies the minimum manning complement necessary for the safe operation of the vessel after considering applicable laws, regulations, and all other factors involved such as size and type of the vessel, installed equipment, and proposed routes of operation.

The consensus of the harbor assist towing vessel segment of the industry is that their current vessel manning scheme does not meet the prescribed manning and credentialing requirements when temporarily operating outside the Boundary Line. In an effort to avoid disruption to this segment of the industry, this policy letter provides guidance for the OCMI to exercise discretion with enforcing regulations, as appropriate, 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.

For full details, view or download Policy Letter 19-01.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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