Items to check:

• Means to immediately establish manual control of the ship's steering
• A competent person is ready at all times to take over steering control
• The changeover from automatic to manual steering and vice versa is made by, or under, the supervision of the officer in charge of the navigational watch

Regulatory Cites:

33 CFR 164.13 Navigation underway: tankers (including Integrated Tug and Barge combinations)
46 CFR 140.670 Use of auto pilot

Regulatory Cites:

46 CFR 147.60 Compressed gases.
46 CFR 147.70 Acetylene.
46 CFR 147.85 Oxygen.

All crewmembers must be capable of performing their expected duties during emergencies aboard the vessel. It is the Master’s responsibility to facilitate drills and instruction required by 46 CFR 140.420 and record the events in the Towing Vessel Record, official logbook, or as described in the vessel’s TSMS.  It is important for drills to be conducted aboard the vessel as if there were an actual emergency. All crewmembers are responsible for actively participating in drills and instruction, and as far as practicable, have actual use of emergency equipment.

Items to check:

• Vessel records confirming that drills and instructions have been performed for:
  • Abandoning the vessel
  • Recovering persons from the water
  • Responding to onboard flooding
  • Responding to threats to the environment
  • Responding to other threats to life or property deemed necessary to particular vessel operations
• Vessel records confirming that monthly drills and instructions have been performed for response to fire aboard the vessel as required by 46 CFR 142.245
• Vessel records confirming that drills and instructions have been performed for launching a skiff to abandon ship or recover a person overboard (if the skiff is listed as emergency equipment)
• Vessel records confirming that instructions have been performed for the use of davit-launched life rafts (if installed on vessel)
• Vessel records confirming that drills and instructions have been performed for the launching and use of a rescue boat during a man-overboard situation (if vessel is equipped with a rescue boat)

Regulatory Cites:

46 CFR 140.420 Emergency drills and instruction
46 CFR 140.915 Items to be recorded
46 CFR 142.245 Requirements for training crews to respond to fires

Formalized emergency station bills must be posted aboard all towing vessels when crewmembers perform rotating watches, or when the vessel is outfitted with overnight accommodations. Emergency duties and duty station information must be posted at each operating station and common crew areas.  All crewmembers are responsible for actively participating in shipboard safety initiatives such as vessel familiarization, emergency drills and training.

Items to Check:

• Verify duty station information has been posted
• Verify that crewmembers are familiar with their assigned emergency duties

Regulatory Cites:
46 CFR 15.405 Familiarity with vessel characteristics
46 CFR 15.1105 Familiarization and basic training (BT)
46 CFR 140.405 Emergency duties and duty stations  

Additional Guidance:

NVIC 07-82 Sample Format of Vessel or Facility Station Bill

All towing vessels are required to perform pre-voyage inspections and tests of specific systems prior to getting underway.  Specific inspections and tests are determined by towing vessel length (over or under 39.4 feet in length) and must be recorded in the TVR, official logbook, or in accordance with the towing vessel’s TSMS.

Items to Check:

• Verify log entries confirming pre-voyage inspections have been completed. 

Regulatory Cites:

33 CFR 164.01 Applicability

33 CFR 164.80 Tests, inspections, and voyage planning. Towing vessels exceeding 39.4 feet or more in length.
46 CFR 140.615 Examinations and tests. Towing vessels less than 39.4 feet in length.
46 CFR 140.915 Items to be recorded

All towing vessels, regardless of compliance option chosen, must have established procedures in place for preventing falls overboard and recovering persons in the water as required by 46 CFR 140.425. These procedures should not be confused with the fall overboard requirements of the Safety and Health Plan in 46 CFR 140.510.

Regulatory Cites:

46 CFR 140.425 Fall overboard prevention
46 CFR 140.510 Identification and mitigation of health and safety hazards

Items to check:

• All towing vessels must be equipped with an industrial type first aid kit that is appropriate to the vessel’s operational conditions and crew size.
• If the towing vessel is operating on oceans, coastwise, or Great Lakes, it must also have a means to take blood pressure readings, splint broken bones, and apply large bandages for serious wounds.

Regulatory Cites:

46 USC 11102 Medicine chests

46 CFR 140.435 First aid equipment

Additional Guidance:
DHHS Publication No. (PHS) 84-2024 The Ship's medicine chest and medical aid at sea

Regulatory Cite:

46 CFR 147.50 Fuel for cooking, heating, and lighting.

Requirements to operate vessels in accordance with all applicable laws and regulations for the safety of life, property, and the environment are stated in 46 CFR 140.205.

Items to check:

• Ensure that vessels operating under a TSMS have addressed and are operating to the TSMS elements prescribed in 46 CFR 138.220. Policies and procedures of the TSMS should clearly state the company’s requirements for vessel maintenance, surveys, safety, environmental protection, security, emergency preparedness, company management organization and addressing non-conformities.
• Verify that the towing vessel is properly manned.  Crew complement shall match the COI manning requirement.
• Ensure that each crewmember aboard has their MMC (if required).
• Ensure that each crewmember aboard that is not required to have an MMC has a valid alternate form of identification.

Regulatory Cites:

33 CFR 101.515 TWIC/Personal Identification
46 CFR 15.515 Compliance with certificate of inspection
46 CFR 15.535 Towing Vessels
46 CFR 138 Towing Safety Management Systems (TSMS)
46 CFR 140.205 General Vessel Operation

Labels and placards for hazardous materials transportation:

Regulatory Cites:

46 CFR 147.15 Hazardous ships′ stores permitted on board vessels.
46 CFR 147.30 Labeling.
49 CFR 172.101 Purpose and use of hazardous materials table.
49 CFR 173.2 Hazardous materials classes and index to hazard class definitions.
49 CFR 173.2(a) Classification of a material having more than one hazard.

All towing vessels must have an operational Safety and Health Plan in place no later than July 22, 2019. New towing vessels must have a Safety and Health Plan in place upon initial operations.  The primary objective of a Safety and Health plan is to identify and implement procedures for the management of health and safety issues aboard the towing vessel.  46 CFR 140, Subpart E (Safety and Health) establishes the general contents of the Safety and Health Plan as well as identification and mitigation requirements for 14 specific safety and health concerns.  The Safety and Health Plan shall also contain specific training requirements associated with the plan.

Safety and Health plan procedures shall address the reporting of unsafe conditions, proper use of equipment, ensuring equipment is in proper working order, availability of proper PPE, fall overboard prevention, and control measures for addressing identified safety issues.  The safety and health topics identified in Subpart E are the minimum requirements for a Safety and Health Plan and may be expanded to address vessel specific hazard awareness.

The Safety and Health Plan shall be readily available aboard the towing vessel and may be a standalone document or incorporated into the TSMS.  Towing vessels operating under an existing safety management system may already have the elements of the Safety and Health Plan covered within their SMS. 

There is no requirement to submit Safety and Health Plans to the Coast Guard or TPO for approval; however, the plan is subject to review during inspections and audits.

Items to Check:

• Procedures implemented for reporting unsafe conditions
• Records of any health and safety incidents that occurred on board the vessel
• Machinery and equipment not in proper working order removed or made safe through marking, tagging, or covering; or otherwise made unusable.
• Appropriate Personal Protective Equipment (PPE) available for all personnel
• PPE cleaned, maintained, and repaired in accordance with manufacturer’s requirements
• All personnel trained in the proper use, limitations, and care of PPE
• Vessel, including crew’s quarters and the galley in sanitary condition
• Procedures in place to identify and mitigate health and safety hazards:
  • Tools and equipment
  • Slips, trips, and falls
  • Working aloft
  • Hazardous materials;
  • Confined space entry
  • Blood-borne pathogens and other biological hazards
  • Electrical
  • Noise
  • Falls overboard
  • Vessel embarkation and disembarkation (including pilot transfers)
  • Towing gear, including winches, capstans, wires, hawsers and other related equipment
  • Personal hygiene
  • Sanitation and safe food handling
  • Potable water supply
• All crewmembers provided with the following health and safety information and training (as applicable to the vessel) within 5 days of employment :
  • Content and procedures of the health and safety plan
  • Procedures for reporting unsafe conditions
  • Proper selection and use of PPE
  • Safe use of equipment including deck machinery, rigging, welding and cutting, hand tools, ladders, and abrasive wheel machinery
  • Hazard communication and cargo knowledge
  • Safe use and storage of hazardous materials and chemicals
  • Confined space entry
  • Respiratory protection
  • Lockout/Tag-out procedures
• Refresher training conducted annually
• Individuals, other than crewmembers, provided with sufficient information or training on hazards relevant to their potential exposure on or around the vessel

Regulatory Cites:

29 CFR 1910 subpart I Personal Protective Equipment
46 CFR 140.500 General
46 CFR 140.505 General health and safety requirements
46 CFR 140.510 Identification and mitigation of health and safety hazards
46 CFR 140.515 Training requirements

Pre-task planning, inspecting, and testing are required when hot work must be accomplished in certain locations aboard a towing vessel.  Prior to starting alterations, repairs, welding, cutting, or other fire producing operations within the locations listed in 140.665, a marine chemist must determine the operation can be undertaken with safety – includes the hot work and any required entry.  140.665 also describes the process of inspection and testing in the event a marine chemist is not available.  The safety and health plan shall also address confined space entry procedures which may prescribe additional requirements prior to starting any hot work.

Regulatory Cites:

46 CFR 140.665 Inspection and testing required when making alterations, repairs, or other such operations involving riveting, welding, burning or like fire-producing actions

Additional Guidance:

NFPA 306 Standard for the Control of Gas Hazards on Vessels

Underway navigational operations require pre-voyage planning and continuous updating of the plan throughout the voyage.  Prior to getting underway, the master or navigational watch officer must perform the navigation assessment (a type of voyage plan) for the intended route. The navigation assessment will consider and address operational risks and crew workload demands expected during the voyage. During each navigational watch change, the officers in charge of the navigational watch shall review the assessment including changes within the plan and formally acknowledge the watch change with a log entry in the official logbook, towing vessel record, or in accordance with the TSMS.   Log entries and records of navigation assessments shall be retained for at least one year after the date of the latest entry. 

Certain towing vessels will need to comply with voyage planning requirements of 46 CFR 140.635 and 33 CFR 164.80.   

Items to check:

• Velocity and direction of currents in the area being transited
  Water depth, river stage, and tidal state along the route and at mooring location
• Prevailing visibility and weather conditions and changes anticipated along the intended route
• Density (actual and anticipated) of marine traffic
• The operational status of pilothouse instrumentation and controls, to include alarms, communication systems, variation and deviation errors of the compass, and any known nonconformities or deficiencies
• Air draft relative to bridges and overhead obstructions taking tide and river stage into consideration
• Horizontal clearance, to include bridge transits
• Lock transits
• Navigation hazards such as logs, wrecks or other obstructions in the water
• Any broadcast notice to mariners, safety or security zones or special navigation areas
• Configuration of the vessel and tow, including handling characteristics, field of vision from the pilothouse, and activities taking place onboard
• The knowledge, qualifications, and limitations of crewmembers who are assigned as members on watch and the experience and familiarity of crewmembers with the towing vessels particulars and equipment
• Any special conditions not covered above that impact the safety of navigation

Regulatory Cites:

33 CFR 164.80 Tests, inspections, and voyage planning

46 CFR 140.635 Navigation assessment

46 CFR 140.640 Pilothouse resource management

46 CFR 140.910 Towing vessel record or record specified by TSMS
46 CFR 140.915 Items to be recorded  

Credentialed mariners holding Able Seaman or officer endorsements will be deemed to have met the training requirements in this section.

Items to check:

• Each crewmember must receive training to ensure they are familiar with the following:
• Watchstanding terms and definitions
• Duties of a lookout
• Communication with other watchstanders
• Change of watch procedures
• Procedures for reporting other vessels or objects
• Watchstanding safety.

 Regulatory Cites:

46 CFR 140.645 Navigation safety training

Required navigational safety equipment must be properly maintained and fully functional aboard each towing vessel.  Any navigational safety equipment that fails during a voyage must be repaired at the earliest practical time.  When determining the repair of failed equipment and deciding whether it is safe for the vessel to proceed, prudent seamanship factors such as the condition of equipment, weather conditions, visibility and traffic shall be considered.  Failures of navigation safety equipment and their subsequent repairs are to be recorded in the official log, Towing Vessel Record, or in accordance with the towing vessel’s TSMS if applicable.

Refer to the Navigation Safety Equipment section for more information about specific equipment requirements. 

Regulatory Cites:

33 CFR 164.01(b) Applicability
33 CFR 164.46 Automatic Identification System
33 CFR 164.72 Navigational Safety Equipment Required on Towing Vessels
33 CFR 164.82 Maintenance, failure, and reporting. Towing vessels 39.4 feet or more in length.
46 CFR 140.620 Navigational safety equipment. Towing vessels less than 39.4 feet in length.
46 CFR 140.915 Items to be recorded

Additional Guidance:
NVIC 8-01 CH-2 Approval of Navigation equipment for ships

An official logbook is required when:

• On a voyage between a US port and a foreign port, with the exception of a voyage from a US port to a Canadian port. 
• The vessel is over 100 GRT when on a voyage between a port in the United States on the Atlantic Ocean and port in the United States on the Pacific Ocean. 

The Coast Guard will provide official logbooks to vessel masters, and the required entries are listed within.  Entries, and or corrections to entries, must include the date and time of the entry and name of the person making the entry.

Note: 46 U. S. Code Chapter 113, titled Official Logbooks, lists specific requirements of record keeping within the official logbook.  46 CFR 140.915 lists additional record keeping requirements to be maintained in the official logbook for compliance with Subchapter M.

Items to check:

• Official Logbook contains required entries:

Personnel records – 46 CFR 140.400
Safety orientation – 46 CFR 140.410
Record of drills and instruction – 46 CFR 140.420
Examinations and tests – 46 CFR 140.615
Operative navigational safety equipment – 46 CFR 140.620
Navigation assessment – 46 CFR 140.635
Navigation safety training – 46 CFR 140.645
Oil residue discharges and disposals – 46 CFR 140.655
Record of inspection of towing gear – 46 CFR 140.820
Fire-detection and fixed fire-extinguishing – 46 CFR 142.240

Regulatory Cites:

46 CFR 140.905 Official logbooks
46 CFR 140.915 Items to be recorded
46 USC 11301 Logbook and entry requirements

The towing vessel master is responsible for keeping accurate lists of crewmen aboard with their positions, responsibilities, and information regarding watch changes.  This information shall be entered into the Towing Vessel Record, official logbook, or in accordance with the vessel’s TSMS.

Items to check:

• Verify that entries have been made to account for all crewmen, persons in addition to the crew and passengers aboard.
• Verify that entries have been made indicating changes of the navigational watches, changes of lookouts and engineering watch changes.

Regulatory Cites:

46 CFR 140.400 Personnel records
46 CFR 140.915 Items to be recorded

Items to check:

• Ship's stores refrigerants carried are listed in ANSIO/ASRAE 34-78.

Regulatory Cite:

46 CFR 147.90 Refrigerants.

Additional Guidance:

ASHRAE Refrigerant Designations.

Prior to getting underway for the first time on a particular towing vessel, each new crewmember must receive a safety orientation.  The orientation shall review the crewmember’s duties during various types of emergencies and operational instructions of specific response equipment.  The safety orientation must be documented in the Towing Vessel Record (TVR), official logbook, or as described in the vessel’s TSMS.   

Items to Check:

• Each crewmember has received a safety orientation on the following:
  • His or her duties in an emergency
  • The location, operation, and use of lifesaving equipment
  • Prevention of falls overboard
  • Personal safety measures
  • The location, operation, and use of Personal Protective Equipment
  • Emergency egress procedures
  • The use and operation of watertight and weathertight closures
  • Responsibilities to provide assistance to individuals that are not crewmembers
  • How to respond to emergencies relative to the tow
  • Awareness of, and expected response to, any other hazards inherent to the operation of the towing vessel which may pose a threat to life, property, or the environment.
• Crewmember orientation documented in the TVR, official logbook, or in accordance with the TSMS including:
  • The date of the safety orientation or training;
  • A general description of the safety orientation or training topics;
  • The name(s) and signature(s) of individual(s) providing the orientation or training
  • The name(s) of the individual(s) receiving the safety orientation or training
• Personnel not part of the crew have received a safety orientation on the following:
  • The location, operation, and use of lifesaving equipment
  • Emergency procedures
  • Methods to notify crewmembers in the event of an emergency
  • Prevention of falls overboard

Regulatory Cites:

46 CFR 15.405 Familiarity with vessel characteristics
46 CFR 15.1105 Familiarization and basic training
46 CFR 140.410 Safety Orientation
46 CFR 140.415 Orientation for individuals that are not crewmembers
46 CFR 140.915 Items to be recorded

A chronological record of events must be maintained by all towing vessels with the exception of towing vessels operating in a limited geographic area  (46 CFR 140.910 (a)).  Record keeping requirements for vessels maintaining an official logbook are discussed in 46 CFR 140.905. The TVR may be in paper or electronic form, and must be maintained in accordance with the vessels TSMS.  Entries, and or corrections to entries, must include the date and time of entry and name of the person making the entry.  Required record keeping must be entered into the TVR or as prescribed by the vessel’s TSMS.

Items to check:

• TVR contains required entries:

Personnel records – 46 CFR 140.400
Safety orientation – 46 CFR 140.410
Record of drills and instruction – 46 CFR 140.420
Examinations and tests – 46 CFR 140.615
Operative navigational safety equipment – 46 CFR 140.620
Navigation assessment – 46 CFR 140.635
Navigation safety training – 46 CFR 140.645
Oil residue discharges and disposals – 46 CFR 140.655
Record of inspection of towing gear – 46 CFR 140.820
Fire-detection and fixed fire-extinguishing – 46 CFR 142.240

Regulatory Cites:

46 CFR 140.910 Towing vessel record or record specified by TSMS
46 CFR 140.915 Items to be recorded

Items to check:

• Watertight and weathertight hatches doors, and opening function properly.
• Watertight and weathertight decks and bulkheads properly maintained.
• Except as authorized, all hatches and openings of the hull and deck kept closed.
• All watertight doors in watertight bulkheads closed during operation unless they are being used for transit between compartments.
• All exterior main deck openings kept closed during downstreaming.
• Decks and bulkheads designed to be watertight or weathertight maintained in that condition.
• All watertight doors in watertight bulkheads kept closed except:
  • When in use for transit between compartments.
  • When operating on lakes, bays, and sounds, without a tow during calm weather, and only if the master determines that the safety of the vessel is not compromised.
  • When operating on rivers with a tow, if the master determines the safety of the vessel is not compromise.

Regulatory Cites:

46 CFR 140.605 Vessel stability
46 CFR 140.610 Hatches and other openings
Marine Safety Alert 1-08 Maintaining Vessel Watertight Integrity
NVIC 17-82 Intact Stability of Small Vessels; Recommendation

Work vests are considered safety equipment and shall not be accepted in lieu of any portion of the required number of approved lifesaving appliances.  If work vests are utilized to comply with 46 CFR 140.430 they must be approved under 46 CFR 160.053.

Items to Check:

• All work vests Coast Guard approved under approval series 46 CFR 160.053
• Work vest lights approved under approval series 46 CFR 161.012 or 46 CFR161.112 (SOLAS)
• Work vest storage location properly marked “Work Vest”

Regulatory Cites:

46 CFR 140.430 Wearing of work vests
46 CFR 141.340 Lifejackets
46 CFR 141.350 Immersion Suites
46 CFR 160.053 Work Vests, Unicellular Plastic Foam
46 CFR 161.012 Personal Flotation Device Lights