For those of you who missed it, here’s an extremely interesting and important article by Dom Yanchunas in Issue #121 of Professional Mariner Magazine from back in February: U.S. operators warned not to use 2-watch system in foreign waters.
Safety of Life at Sea (SOLAS) Convention rules require that all vessels over 500 Gross Tons (ITC), as measured under the International Tonnage Convention, on an international voyage have a Safe Manning Document (SMD) issued by their flag state. They’re also recommended for vessels under 500 GT (ITC) as well so as to offer greater protection if a dispute were to arise with port state control inspectors while overseas. To clarify the only two currently recognized license and vessel tonnage equivalencies, 200 GRT (US domestic regulatory tonnage) is equal to 500 GT (ITC) and 1,600 GRT (US) is equal to 3,000 GT (ITC). These SMD’s are issued by the local Coast Guard Marine Inspection Office after a vessel receives a voluntary inspection. They normally require a 3-watch system be used when on an international voyage unless a different crewing level is specifically authorized, and there are other licensing, certification, training and equipment requirements as well.
The article stated that at S.U.N.Y. Maritime College’s Towing Forum last October Coast Guard Office of Vessel Activities chief Capt. Eric Christensen indicated that American operators are asking for trouble if they voyage to Europe without a 3-watch system in place. “Nations in Europe and elsewhere are getting to the point where they are starting to look at vessels that are coming from the United States that they know are not manned properly,” Christensen said. “You need to be cognizant of that.”
Is merely being cognizant of this fact enough? Apparently we’re “earning a bad reputation overseas” according to the Coast Guard, and we’re now considered to be on an operational par with Albania, Barbados and Cambodia in terms of vessel detentions. Albania, Barbados and Cambodia? This is a humiliating distinction for the world’s sole remaining superpower and it has led to a foreign crackdown on visiting US-flagged uninspected towing vessels. According to the article, “When the U.S. begins mandatory inspection of tugboats in a few years, such disruptions are expected to ease.” Maybe, or maybe not. Only if the Coast Guard insists that proper manning and equipment standards that compare with those of modern safety-minded seafaring countries be included in the new inspection regulations will this happen. That’s a huge “if” at this stage of the game.
There is one important thing that the article got wrong: the reasoning that a 3-watch system is necessarily more expensive for the vessel operators doesn’t hold up to even casual scrutiny. No matter what system is used it’s just a cost of doing business that every vessel operator is or would be subject to and it will ultimately be passed on to the customer, who will in turn pass that cost on to their customers and so on down the line. Everybody helps to pay for the better safety standards as the costs are eventually spread out over society at large at the consumer end. The key is making sure that a level playing field exists for everyone. Diligent, effective enforcement of manning regulations will prevent most cheating and thereby largely eliminate the legitimate concern that fly-by-night companies (or sub-standard flag states) will gain a competitive advantage over the others by short-crewing and deliberately bypassing other regulations, practices that are certainly not unheard of today in any case.
You don’t need an M.B.A. from Harvard Business School to figure this stuff out. And the beautiful irony is in the fact that, right now, we’re the sub-standard operators that the others are objecting to. Gotta love it…..
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