CREDENTIALS, DOCUMENTS AND REPORTS
Collapse All Expand All

Vessels equipped with ballast tanks may elect to retain ballast on board or use an alternative environmentally sound method of ballast water management that has been submitted to and approved by the Coast Guard prior to the voyage. If the alternative environmentally sound method of ballast water management in inoperative, the vessel may discharge only the amount of ballast water operationally necessary to ensure the safety of the vessel.  

Many towing vessels on Western Rivers routes use treated city water supplies for ballast.  Under most circumstances, the discharge of treated city water should be considered an alternative environmentally sound method of ballast water management.

There are mandatory ballast water reporting and recordkeeping requirements for towing vessels equipped with ballast tanks.

Regulatory Cites:

33 CFR 151.2060 Reporting requirements
33 CFR 151.2070 Recordkeeping requirements

Additional Guidance:

NVIC 01-18  Ballast Water Management for Control Of Non-Indigenous Species In Waters of the United States

The cognizant OCMI is responsible for establishing manning levels for each towing vessel based on statutory and regulatory requirements and with consideration given to factors including, but not limited to, vessel size, service and route.

Manning guidance and sample manning scales for towing vessels inspected under Subchapter M can be found in Parts B and C of Marine Safety Manual Volume III: Marine Industry Personnel.  Relevant sections are listed below for ease of reference (not all inclusive):

Chapter B1, General Provisions for Vessel Manning (NOTE:  Annex Attachment (1) contains a Suggested Template: Minimum Safe Manning Proposal);

Chapter B2, Section W: Sample Manning Scales for Towing Vessels Inspected under 46 CFR Subchapter M;

Chapter B2, Section X: Manning and STCW Certification Reference Tables (Seagoing Vessels);

Chapter B3, Section B: Impact of International Standards (OCCC ’36, STCW, ITC, SOLAS, IMO Resolution A.1047(20));

Chapter B3, Section C: Masters;

Chapter B3, Section D: Mates;

Chapter B3, Section E: Chief Engineer;

Chapter B3, Section F: Engineers;

Chapter B3, Section G: Master and Mate (Pilot) of Towing Vessels;

Chapter B4, Section D: Deck Department Manning;

Chapter B4, Section E: Engineering Department Manning;

Chapter B5, Section A: Watchstanding Requirements on U.S. Vessels;

Chapter B5, Section C: Work Hour Limitations;

Chapter B5, Section E: International Standards Relating to Working Conditions (STCW, ILO 147, ILO MLC);

Chapter B6, Section A: Manning Requirements

Chapter C2, Section A: Deck Officer Endorsements (Routes, Tonnage, Grade, Equivalents, Trade Restrictions);

Chapter C2, Section B: Engineer Officer Endorsements (Propulsion Power, Grade, Equivalents, Trade Restrictions);

Chapter C2, Section C: Deck Ratings;

Chapter C2, Section D: Engine Ratings;

Annex Attachment (1): Suggested Template – Minimum Safe Manning Proposal; Annex Attachment (3): Master’s Field Guide – U.S. Vessel manning

Regulatory Cite:

46 CFR 15.501 Certificate of inspection

Additional Guidance:

Marine Safety Manual Volume III

A Certificate of Documentation (COD) is valid for one year from date of issue.

A coastwise endorsement entitles a vessel to employment in unrestricted domestic trade, dredging, towing, and any other employment for which a registry, OR fishery endorsement is not required.  If the vessel operates on a foreign voyage it must have a registry endorsement.  

The official number of the vessel, preceded by the abbreviation: “NO.” must be marked in block-type Arabic numerals not less than three inches in height on some clearly visible interior structural part of the hull. The number must be permanently affixed so that alteration, removal, or replacement would be obvious. If the official number is on a separate plate, the plate must be fastened in such a manner that its removal would normally cause scarring of or damage to the surrounding hull area.  

The name of the vessel must be marked on some clearly visible exterior part of the port and starboard bow and the stern of the vessel. It must be made in clearly legible letters of the Latin alphabet or Arabic or Roman numbers not less than four (4) inches in height. If used, name boards must be rigidly attached. The hailing port of the vessel must be marked on some clearly visible exterior part of the stern of the vessel. For vessels with a square bow, the name of the vessel must be marked on some clearly visible exterior part of the bow in a manner to avoid obliteration. The name and hailing port must be marked on some clearly visible exterior part of the stern.

Items to check:

  • Properly endorsed and valid Certificate of Documentation (COD) on board.
  • Official Number properly marked and clearly visible on an interior structural part of the hull.
  • Name of the vessel marked and clearly visible on exterior part of the port and starboard bow and the stern of the vessel.

Regulatory Cites:

46 CFR 67.19 Coastwise Endorsement
46 CFR 67.121 Official Number Marking Requirement
46 CFR 67.123 Name and hailing port marking requirements
46 CFR 67.313 Requirement to have Certificate of Documentation on board

Items to check:  

  • Company participates in a drug testing program or consortium.
  • Operator knowledgeable about general rules for intoxicant use.
  • Employee Assistance Program in place:
    • Display and distribution of informational material:
      • A community service hot-line telephone number for crewmember assistance.
      • Employer’s policy regarding drug and alcohol use in the workplace.
    • A training program the includes:
      • The effects and consequences of drug and alcohol use on personal health, safety, and work environment.
      • The manifestations and behavioral cues that may indicate drug and alcohol use and abuse.
  • Vessel carries devices or has arrangements to perform alcohol testing w/in 2 hours & drug testing w/in 32hrs after a serious marine incident.

Regulatory Cites:
46 USC 3301 Vessels subject to inspection
46 CFR 4.03-1 Marine casualty or accident
46 CFR 4.03-2 Serious marine incident
46 CFR 4.06 Mandatory chemical testing following serious marine incidents involving vessels in commercial service
46 CFR 4.06-1 Responsibilities of the marine employer
46 CFR 4.06-3 Requirements for alcohol and drug testing following a serious marine incident
46 CFR 16.105 Definitions of terms used in this part (Chemical Testing)
46 CFR 16.210 Pre-employment testing requirements
46 CFR 16.220 Periodic testing requirements
46 CFR 16.230 Random testing requirements
46 CFR 16.240 Serious marine incident testing requirements
46 CFR 16.250 Reasonable cause testing requirements
46 CFR 16.260 Records
46 CFR 16.401 Employee Assistance Program (EAP)

Click here to expand contentClick here to collapse content  FCC

Towing vessels 26 ft or over in length, while underway on the Navigable Waters of the United States, must have two radiotelephones on board capable of operation from its navigational bridge, and capable of transmitting and receiving on the frequency or frequencies within the 156-162 MHz band for the exchange of navigational information. The radiotelephones must be capable of transmitting and receiving on VHF FM channel 13 (156.65 MHz) while also maintaining a continuous listening watch on the International Distress and Calling Channel, VHF FM Channel 16 (156.800).  A single VHF-FM radio capable of scanning or sequential monitoring (“dual watch” capability) will not meet the requirements for two radios.  Some towing vessel will also need the capability to transmit and receiving on VHF FM channel 67 (156.375 MHz) – see 33 CFR 166.200.  Vessels operating within a Vessel Traffic Service area must meet additional transmitting and receiving capabilities – see 33 CFR Table 161.12(c).

FCC Ships Station License:

Radio stations in the maritime service must be licensed by the FCC individually or by fleet. Licenses will normally be issued for a term of ten years from the date of original issuance, or renewal. On the license under Radio Service, it should read SB – Ship Compulsory Equipped.  If it says SA – Ship Recreational or Voluntarily Equipped under Radio Service it should be corrected at once.

Station Logs:

Details regarding applicable radiotelephone log entries can be found in 47 CFR 409(f).  Per 47 CFR 80.409(a)(1), the log must be kept in an orderly manner and may be kept electronically or in writing.  

Regulatory Cites:

33 CFR Part 26 Vessel bridge-to-bridge radiotelephone regulations
33 CFR 26.03 Radiotelephone required
33 CFR 166.200 Shipping safety fairways and anchorage areas, Gulf of Mexico
47 CFR 80.13 Station license required
47 CFR 80.25 License term
47 CFR 80.161 Operator requirements of the Great Lakes Radio Agreement
47 CFR 80.163 Operator requirements of the Bridge-to-Bridge Act
47 CFR 80.409 Station logs
47 CFR 80.951-971 Radiotelephone installation required for vessels on the Great Lakes
47 CFR 80.1065 Global Maritime Distress and Safety System (GMDSS) – Applicability

Hazardous Condition means any condition that may adversely affect the safety of any vessel, bridge, structure, or shore area or the environmental quality of any port, harbor or Navigable Water of the United States. It may, but need not, involve collision, allision, fire, explosion, grounding, leaking, damage, injury or illness of a person on board, or manning shortage.  

Regulatory Cites:

33 CFR 160.113 Prohibition of vessel operation and cargo transfers
33 CFR 160.204 Exemptions and exceptions

Towing vessels that are subject to the load line requirements must have load lines accurately marked amidships, port and starboard; and must have a valid load line certificate to document the load line survey, the proper placement of the load line marks and any restrictions on vessel operations. 

Items to check:

  • Valid load line certificate on board
  • Hull properly marked.

Regulatory Cites:

46 CFR 136.250 Load lines
46 CFR 42.07-1   Load lines required
46 CFR 42.50 Load Line Certificates – Model Forms

It is the responsibility of the owner, managing operator, and master to ensure that their vessels are operated in accordance with safe manning, working hours and watchkeeping requirements of applicable laws & regulations.  This includes making certain that their vessels are crewed with personnel of appropriate grades who have been properly trained and certificated.

The COI serves as the Safe Manning Document (SMD) for the vessel and states the minimum numbers and categories of credentialed crewmembers necessary for safe operations.  No vessel may be navigated unless it has in its service and onboard the crew complement required by the COI.  In certain cases, a vessel is permitted to be navigated without all of the required positions being filled - refer to Marine Safety Manual Volume III.B1.I and 46 CFR 15.725 for details.

Crewmembers filling a position that requires a MMC must hold signed, appropriate and valid credentials for the position in which they are engaged. 

Required MMC endorsements for service on towing vessels can be found in Marine Safety Manual Volume III.B3 Figure B3-2: Towing Endorsement Table (2014, 2017).

If the vessel is 26 ft. or more in length and equipped with radar, each Master or Mate (Pilot) must hold an endorsement as radar observer.

Certain towing vessels are also required to employ credentialed mariners in their deck department (i.e. ABs).  Refer to Marine Safety Manual Volume III.B4.D for details.

Watchstanding:

The master is responsible for ensuring that adequate watches are established for both underway and in-port operations that require watchkeeping personnel.  Refer to Marine Safety Manual Volume III.B5 for details.

Gross
Tonnage 
Route 

 Length of
 Voyage  

Watch
System 
 <100 GRT  Domestic-Any  <12 Hours  1
 <100 GRT  Domestic-Any  >12 Hours  2
 <200 GRT  Any  Any Length  2
 >200 GRT  L/B/S, Rivers  Any Length  2
 >200 GRT  Oceans, Coastwise, Great Lakes  <600 miles  2
 >200 GRT  Oceans, Coastwise, Great Lakes  >600 miles  3

 

The master is also responsible to ensure that workhour limitations are not exceeded. Vessels subject to STCW have additional work hour limits & schedule/recordkeeping requirements.  Refer to Marine Safety Manual Volume III.B5 for details.

Items to check:

  • For all routes:
    • Vessel manned in accordance with the Certificate of Inspection.
    • Merchant Mariner Credentials for crewmembers.
    • Individual(s) in charge of navigating or maneuvering the vessel hold an appropriate Merchant Mariner Credential with proper endorsement(s) for the vessels size and route.
    • Valid Transportation Worker Identification Credential (TWIC) for crewmembers needing unescorted access.
  • For coastwise and oceans routes only: 
    • Crewmembers in a position requiring an STCW endorsement have the proper STCW endorsement(s).
    • Crewmembers completed STCW familiarization a basic safety-training.
    • Vessel complies with STCW Principals of Watchkeeping.
    • Crewmembers comply with rest period requirements of STCW.

Regulatory Cites:

33 CFR 89.25 Waters specified by the Secretary
46 CFR 10.107 Definitions in subchapter B
46 CFR 10.109 Classification of endorsements
46 CFR 10.203 Requirement to hold a TWIC and a merchant mariner credential
46 CFR 10.205 Validity of a merchant mariner credential
46 CFR 15.610 Master and mate (pilot) of towing vessels
46 CFR 15.705 Watches
46 CFR 15.720 Use of non-U.S.-credentialed personnel
46 CFR 15.725 Sailing Short
46 CFR 15.812 Pilots
46 CFR 15.815 Radar Observers
46 CFR 15.840 Able Seaman
46 CFR 15.1105 Familiarization and basic training (BT)
46 U.S.C. subtitle II part E Merchant Seamen Licenses, Certificates, and Documents
46 USC 7110 Exhibiting Licenses
46 USC 8104 Watches
46 USC 8304 Implementing the Officers’ Competency Certificates Convention, 1936
46 USC 8702 Certain crew requirements

Additional Guidance:

NVIC 03-16 Licensing and Manning for Officers of Towing Vessels
NVIC 03-07 Transportation Worker Identification Credential (TWIC) Program
Marine Safety Manual Volume III (2017) Marine Industrial Personnel

For State registered towing vessels, a casualty or accident report must be submitted to the reporting authority of the state who issued the state number, or to the state where the casualty or accident occurred.  

For all other towing vessels involved in a marine casualty, notification must be made to the nearest Coast Guard Sector office immediately after addressing resultant safety concerns and, within five days, file a written report of any marine casualty required to be reported under 46 CFR 4.05-1.

Regulatory Cites:

33 CFR 173.51 Casualty and accident reporting
46 CFR 4.03-65 Significant harm to the environment
46 CFR 4.05-1 Reports of potential vessel casualty
46 CFR 4.05-10 Written report of marine casualty

Items to check:

  • Written record of garbage discharge or disposal operations. (Only required for oceangoing vessels of 400 gross tons and above)

Oceangoing vessels 40 ft or more in length, or equipped with a galley and berthing, must have a written Waste Management Plan. The plan must provide for the discharge of garbage by means that meet Annex V of MARPOL 73/78, and 33 CFR 151.51 through 151.77 describing procedures for collecting, processing, storing, and discharging garbage; and designates the person who is in charge of carrying out the plan.  

Vessels 26 ft or more in length must have one or more garbage placards displayed in prominent locations and in sufficient numbers so that they can be read by the crew.  Each placard must be at least nine inches wide by four inches high, made of a durable material, and have lettering at least 1/8 inches high.

 

Regulatory Cites:

33 CFR 151.51 Applicability – Garbage Pollution and Sewage
33 CFR 151.57 Garbage management plans
33 CFR 151.59 Placards
33 CFR 151.63 Shipboard control of garbage
33 CFR 151.77 Exceptions for emergencies and health risks

MARPOL 73/78, Annex VI entered into force for the United States on January 8, 2009.  The guidance in enclosure (1) of CG-543 Policy Letter 09-01 should be used during Sub M inspections/surveys respectively, to ensure all inspected or uninspected towing vessels operating in U.S. waters comply with the provisions of MARPOL 73/78, Annex VI. OCMIs should bring this policy to the attention of appropriate individuals in the marine industry.

The table below summarizes the various Annex VI compliance documentation scenarios:

Inspection Status

Gross Tonnage

Route

Annex VI Documentation

Inspected

≥ 400 ITC

International

IAPP Certificate and
EIAPP Certificate, if appropriate

Inspected

≤ 400 ITC

International

Annex VI endorsement on COI

Inspected

Any gross tonnage

Domestic

COI

Uninspected

Any gross tonnage

Domestic

None Required

Items to check:

  • Checklists can be found for specific vessels depending on Gross Tonnage and Route in Appendix A of Enclosure (1) to CG-543 Policy Letter 09-01.

Regulatory Cites:

40 CFR Part 89 Control of Emissions from New and in-use Nonroad Compression-Ignition Engines
40 CFR Part 94 Control of Emissions from Marine Compression-Ignition Engines
40 CFR Part 1039 Control of Emissions from New and in-use Nonroad Compression-Ignition Engines
40 CFR Part 1042 Control of Emissions from New and in-use Marine Compression-Ignition Engines  and Vessels

Additional Guidance:

CG-543 Policy Letter 09-01 Guidelines for ensuring compliance with Annex VI to the International Convention of the Prevention of Pollution from ships (MARPOL) 73/78; prevention of air pollution from ships.

Click here to expand contentClick here to collapse content  MTSA

MTSA applicability for towing vessels is based on the MTSA status of barges being towed.  The ISPS Code applies to vessels on international voyages. Because MTSA includes ISPS requirements, compliance with MTSA satisfies ISPS requirements for U.S. vessels on an international voyage.  

MTSA is applicable to all towing vessels greater than 26 feet in length engaged in towing a barge or barges subject to 46 CFR subchapters D or O.  MTSA is also applicable to towing vessels that engaged in towing a barge or barges that carry certain dangerous cargo in bulk that are subject to 46 CFR subchapters I.  The above MTAS applicability does not apply to a towing vessel that temporarily assists another vessel engaged in towing a barge or barges; shifts a barge or barges at a facility or within a fleeting facility; assists sections of a tow through a lock; or provides emergency assistance.  

Towing vessels subject to MTSA must be operated in accordance with their approved Vessel Security Plan (VSP) or Alternate Security Program (ASP) at all time.  The VSP or ASP may include variable security measures to cover towing operations that don’t involve barges subject to MTSA. Security plan approval is valid for five years from the date of approval.  VSPs and ASPs must have an initial verification upon plan approval, and verification once in five years by the Coast Guard.  

Regulatory Cites:

33 CFR 160.204 Exemptions and exceptions
33 CFR 104.105 Applicability – towing vessels
33 CFR 104.120 Compliance documentation
33 CFR 104.410 Submission requirements

Additional Guidance:

NVIC 4-03 change 3 Guidance for verification of vessel security plans

Towing vessels must carry currently corrected editions of publications for the area to be transited.

Items to check:  

  • Charts or maps for area of operation
  • USCG Light List for area of operation
  • ACOE Notices to Navigation or USCG Local Notice to Mariners (LNM)
  • River-current tables (if available)National Geospatial-Intelligence Agency (NGA (formerly NIMA)) Notices to Mariners or USCG Local Notice to Mariners (LNM)Tidal-current or river-current tables
  • Tide tables
  • USCG Coast Pilot
  • Copy of VTS Rules
  • Inland Navigation Rules on board

Regulatory Cites:

33 CFR 164.72 Navigational-safety equipment, charts or maps, and publications required on towing vessels
46 CFR 140 Subpart G - Navigation and Communication Equipment

Additional Guidance:

NVIC 01-16 Use of electronic charts and publications in lieu of paper charts, maps and publications

Towing vessels 26 ft or longer must have a placard posted in each machinery space, or at the bilge and ballast pump control station.

The Person-In-Charge of any transfer of oil requiring a Declaration of Inspection must hold a valid credential authorizing service as a master, mate, pilot, engineer or hold a valid MMC endorsed as Tankerman-PIC or carries a letter satisfying the requirements of 33 CFR 155.715 and designating him or her as a PIC.  

Vessels with a capacity of 250 or more barrels (10,500 gallons) of oil must have transfer procedures that meet the requirements of 33 CFR Parts 155 and 156 for transferring oil to or from the vessel, and from tank to tank within the vessel. The procedures must be permanently posted or available at a place where the procedures can be easily seen and used by members of the crew when engaged in transfer operations.  

Written records must be available with the name of each person currently designated as PIC of transfer operations, the date and result of the most recent tests and inspections, the hose information if not marked on the hose, and declarations of inspection for transfer operations completed during the most recent month.  

Vessels carrying oil as a secondary cargo must have an approved Vessel Response Plan divided into sections described in 33 CFR 155.1030, and a geographic-specific appendix for each COTP zone the vessel operates in.  Vessels over 400 ITC or that have a fuel capacity of over 2,500 barrels must have a response plan  

Regulatory Cites:

33 CFR 138.100 Non-owning operator’s responsibility for identification
33 CFR 154.500 Hose assemblies
33 CFR 155.450 Placard
33 CFR 155.710 Qualifications of person in charge
33 CFR 155.715 Contents of letter of designation as a person-in-charge of the transfer of fuel oil
33 CFR 155.720 Transfer procedures
33 CFR 155.740 Availability of transfer procedures
33 CFR 155.750 Contents of transfer procedures
33 CFR 155.820 Records
33 CFR 155.1030 General response plan requirements
33 CFR 155.1045 Response plan requirements for vessels carrying oil as a secondary cargo
33 CFR 155.1065 Procedures for plan submission, approval, requests for acceptance of alternative planning criteria, and appeal
33 CFR 156.150 Declaration of inspection
33 CFR Part 155 Oil or hazardous material pollution prevention regulations for
33 CFR Part 156 Oil and hazardous material transfer
46 CFR Part 10 Merchant mariner credential

Additional Guidance:

NVIC 01-05 change 1 Interim guidance for the development and review of response plans for nontank vessels

Items to check:

  • Towline inspection records documented in the TVR, official logbook, or  in accordance with TSMS:
  1. Type of towline
  2. Size of towline
  3. Size and service of each towline
  4. Initial minimum breaking strength
  5. Record of each retest of the towline’s minimum breaking strength Visual inspection of towline in accordance with manufacturer’s recommendations, or at least monthly, and whenever the serviceability of the towline is in doubt
  6. Dates when examinations were performed
  7. Identification of each item of towing gear examined
  8. Name(s) of the person(s) conducting the examinations  

Regulatory Cites:

46 CFR 140.820 Recordkeeping for towing gear
33 CFR 164.74 Towline and terminal gear for towing astern
33 CFR 164.76 Towline and terminal gear for towing alongside and pushing ahead

Other Guidance:

NVIC 5-92 Guidelines for Wire Rope Towing Hawsers

The vessel must be marked on each side of the forward half of the vessel with a number issued on a certificate of number by the issuing authority in the State in which the vessel is principally used. The number must be in plain vertical block characters of not less than 3 inches in height; contrast with the color of the background and be distinctly visible and legible; must have spaces or hyphens that are equal to the width of a letter between letter and number groupings (Example: DC 5678 EF or DC-5678-EF); and read from left to right. Some states require a commercial endorsement on the certificate of number.

Items to check:

  • Valid state (commercial) Certificate of Number on board.
  • Hull properly marked.

Regulatory Cites:

33 CFR 173.15 Vessel number required
33 CFR 173.21 Certificate of number required
33 CFR 173.27 Numbers: Display; size; color

Items to check:  

  • Pre departure records of visual inspections (required for a vessel embarking on a voyage of more than 24 hours or when a new master/operator assumes command):
    • Steering Systems:
      • Main steering gear from alternative power supply (if installed)
      • Verify accuracy of rudder-angle indicator
      • Visual inspection of steering gear and linkage
    • Navigational Equipment.
    • Communications:
      • Internal vessel control communications
      • Vessel-control alarms (if installed)
    • Lights:
      • Navigation lights
      • Search lights
    • Terminal Gear:
      • Tackle
      • Connections of bridle and towing pendant (if applicable)
      • Chafing gear
      • Winch brake (if installed)
    • Propulsion Systems:
      • Main propulsion machinery
      • Machinery
      • Devices for monitoring machinery  
  • Records of lifesaving equipment tests and inspections:
    • Date of inspection
    • Number or other identification of each unit tested or inspected
    • Result of inspection or test
    • Name of crewmember, surveyor or auditor conducting inspection or test
    • Receipts and or records of tests/inspections maintained for one year  
  • Records of firefighting equipment tests, inspections, and maintenance:
    • Inspection and test records (at least every 12 months) for the following:
      • Hand portable fire extinguishers
      • Semi portable fire-extinguishing systems
      • Fire detection systems
      • Fixed fire-extinguishing systems:
        • Ventilation
        • Machinery shutdowns
        • Pressure-operated dampers
    • Date of inspection and tests performed
    • Number or other identification of each unit tested or inspected
    • Name of crewmember, surveyor or auditor conducting inspection or test
    • Receipts and or records of tests/inspections maintained for one year  

Regulatory Cites:

33 CFR 164.80 Tests, inspections, and voyage planning
46 CFR 140.615 Examinations and tests
46 CFR 141.235 Inspection, testing, and maintenance (lifesaving equipment)
46 CFR 142.240 Inspection, testing, maintenance, and records (firefighting equipment)
46 CFR 199.190 Operational readiness, maintenance, and inspection of life saving equipment