The Arrival of SubChapter M - Reality Check


Published by Donald Bates-Brands at Shakespir

Text Copyright 2017 Donald Bates-Brands


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Table of Contents

The Arrival of SubChapter M – Reality Check

Abut Donald Bates-Brands

Other Books by Donald Bates-Brands


As of June 20, 2016 Subchapter M is officially here. It is supposed to address many issues in the towing industry and make our profession much safer. Everything has been addressed including fire fighting, supplies, record keeping, drills, surveys, inspections, training, navigation, security, lifesaving, etc. Everything, except for Manning and Work Hours. Everything except for the most important issue in the entire package. We can have the best equipment, with the best shoreside support team, with the best policies, training and guidance, but what does any of that matter if the crew is exhausted? Exhausted crews get injured more often, make bad decisions and fall asleep on watch. Manning is the most important part of Subchapter M.

I started working on tugs back in 1975. In June of 2016 I finally retired after 41 years on tugboats most of them as Captain. From 1967 until 1975 I was in the USCG and was discharged with the grade of Quartermaster First Class. All together I have been going to sea for 48 years and frankly I am worn out and burnt out. Forty-one years of standing watch 6 on and 6 off takes its toll. Over half a year following my retirement; my biological clock still has trouble figuring out when I should be asleep and awake. Even in my prime it took 2-3 days to make the transition from work to time home and then from home to work. Many people I have talked to have said the same thing. I used to say that I loved the work and hated the job.

So, why did we do it? There was a certain feeling of purpose, tranquility and excitement that energized us into constantly going back for more. There was the scenery in all of its many moods that separated us from the shore side rat race. An old saying described tug boating as long periods of boredom separated by moments of sheer terror. The sheer terror came in with maneuvering barges in seemingly impossible maneuvers, drawing energy from the close calls and afterwards enjoying the exhilaration of having succeeded. I think there was also a certain pride in seeing how far you could push yourself with little sleep and still get the work done. There were many downsides of course. The isolation without cell phones took a terrible toll on marriages and when things did go wrong, the responsibility for millions of dollars of cargo, equipment and lives weighed down on us with a terrible pressure.

The toll in accidents had to stop. It was ruining families, the environment and the company bottom line. In the early 90’s regulations started pouring in. It was needed. It was time for the industry to grow up and take responsibility for its actions. But the old bottom line persisted and while costs for equipment and maintenance kept rising to meet ever tighter regulation; the companies had to cut costs in other areas. Crew manning came under close fiscal scrutiny.

In the “good old days” working on seagoing tugs we would have a Captain, mate, chief engineer, second engineer, 2 able bodied seaman, 1 ordinary seaman and a cook. That is an 8 man crew! Over the years the crew on similar sized boats has been whittled down to four in many cases! Sometimes less. In some local harbor operations a one man crew is accepted. Can I be sure this is true? I’ve already had to do it myself!

People should not be expected to board a vessel and be totally devoted to it for every minute of every day. We don’t think this way anymore and we shouldn’t be expected to. Crews do need to be totally devoted to their jobs when on watch. This is not the time to be playing computer games or watching TV. It is not the time to be chatting with family on the cell phone. But, that being said we all also need time to get out of our “day job” and pursue other endeavors. We all need 7 to 8 hours of unbroken sleep every day. We also need a certain amount of down time to watch TV and engage in other means of relaxation. Seagoing ships with a 4 on 8 off schedule commonly have gyms and such. Of course a gym is just not possible given the size of most tugs, but with 6 on 6 off two watch schedules there is not much of anything else that is possible to break up the grind, the stress and the boredom.

The problem with the two watch system is threefold. A man needs time off watch to eat, bathe, and enjoy some form of safe diversion, as well as to get 8 hours of continuous sleep. With little time for diversion off watch, you will tend to find it on watch. Watch time is work time and full attention needs to be paid to the work. There are not enough hours in the day to properly do all of the drills and paperwork and get the job done properly with the current manning and watch schedule.

This is going to encourage filling out paper with little regard for actually carrying out inspections or meeting anything other than “paper” requirements. The individual who is taking these shortcuts will not feel any job satisfaction. Job satisfaction is all important in maintaining the morale of a tugboat. More than many other occupations; our job defines who we are. This is one of the factors in not being able to attract new people to this work. And, then there is the really dedicated individual who tries to accomplish the “letter of the law”, but quickly gets tired and burnt out. This is not a safe condition.

Exhaustion has been sited as a common cause of “human factor” accidents. Estimates ranging from 50% to 80% of accidents have been ruled to these causes. Nevertheless the Coast Guard has determined that current manning is adequate. Sea going ships have long stood a standard 4 on 8 off schedule. They need this to stand an alert watch on the open ocean. But tugs and offshore supply vessels going less than 600 miles are only required to have a two watch rotation even though they are running in far more of a close quarters situation than their colleagues on the larger vessels in open water.

The inadequacy of this is demonstrated by the July 30, 2000 collision with the tug Chinook of Sea Coast Towing hitting the Evergreen Point Bridge in Seattle, WA. The Captain had rest before his watch, but he had worked 30 of the previous 51 hours before the incident. He had fallen asleep before the collision and was found to be in violation of the 12 hour rule. He had been called off watch 3 times during the past 51 hours for ship’s business. The Coast Guard still suspended his license and Sea Coast Towing got a $11,000 fine. Further investigation betrayed 9 other violations of the 12 hour rule during the three week period before this accident.

In August of 2000 the Seabulk Georgia was enroute to supply an offshore oil rig. The mate had been standing a 6 hour on and 6 off watch schedule. The vessel collided with the oil platform removing the wheelhouse and the mate’s legs. The mate had no memory of the incident as he had apparently fallen asleep just before it. The Captain was not on watch at the time, but stated that he frequently had to put in 20 hour days.

The Department of Transportation has been studying shipboard fatigue since their paper “Shipboard Crew Fatigue, Safety and Reduced Manning of July 1990”. The Coast Guard has considerable accident data in their own records and yet, the Final Rule for the Inspection of Towing Vessels dated June 20, 2016 states: “We agree that a trained, well-rested lookout would be more likely to help avoid towing accidents than a tired lookout who is not adequately trained. The rule does not contain specific training or hours of work requirements for lookouts, although such training and fatigue management may be part of a TSMS. We are considering developing a separate rulemaking for hours of service and crew endurance management based on our authority under 46 U.S.C. 8904©. If we do so, we will publish a separate document in the Federal Register. We have made no changes from the proposed rule based on these comments.” and later they continue: “In accordance with 46 CFR 15.501, the Coast Guard will specify the minimum manning for each towing vessel” (wasting more time to discover the obvious) “in all of the vessel’s areas of operation on the vessel’s COI, including international and domestic operations… We do not envision an appreciable increase in the number of qualified individuals needed to man inspected towing vessels. The influence of market forces on the number of individuals seeking to become credentialed operators is beyond the scope of this rulemaking.”

This last comment implies that reduced manning is necessary because a sufficient quantity of skilled operators are not available. Sufficient qualified operators are hard to find because the working conditions are so onerous that skilled people want to use their abilities somewhere else that is more rewarding. We lost a number of people to the NY tugboat strike of 1988. The pay had been good and was compensation for the arduous hours. With massive pay cuts, benefit losses, and loss of cooks the men walked. The companies assumed that they could just wait out the situation with scabs, because eventually the strikers would have to come back. Some did; many didn’t. Many left the industry. I personally know of individuals going to jobs as electricians, car salesmen, operating a B & B, etc. People would be available if the working conditions weren’t so onerous.

Consider that the average work week ashore in the United States is now around 46.7 hours according to a 2013/2014 Gallup poll. On tugs we are putting in an official 84 hour work week. I say official because the crew is still onboard the vessel and subject to being called out 24 hours a day. And they are called out; frequently. Crew problems, company requirements, finishing mandated paperwork before inspections and the like ensure this. Work days can be as long as 20 hours or more. This does not show in company records because that would document violation of the 12 hour rule.

Tug boats have been the step child of the marine transportation industry for too long. The Coast Guard itself considers tug licenses to be “lower level”. The 12 hour rule, which is almost impossible to have work properly with the two watch system, has itself been periodically under attack by industry. Industry wants a longer day than 12 hours. Collateral duties are constantly requiring both operators to be up at the same time in many situations. These duties include making and breaking tows, docking & sailing, running in reduced visibility, “soaking the bar”, drills, safety meetings and paperwork. Now we have Subchapter M that has been described as carrying with it onerous paperwork and reporting requirements. Just when are these already overworked operators supposed to do this work? Many tugs are on the move constantly leaving no time to do this work “on watch”.

On ships you have the Master to do to the paperwork. He is not a watch stander. You also have three watch standers. On a tug the Master is up half the day as a watch stander & has to keep up the paperwork and ensure compliance with these regulations as well.

A maritime vessel needs to have redundancy in parts, gear, fuel and crew size to allow for the unforeseen and emergencies. All of these have been sacrificed in recent years to save money! If someone gets hurt, someone else has to be available and it’s very difficult to get a cab to pull up five miles off Atlantic City to deliver the replacement!

Now let’s put a new man on board. I think we can all agree that no matter how much classroom training you have; you still need more training on board in “the real world”. New people need to be shown the ropes. If you only have two people up at any given time, one has to steer and the other man is alone on deck. How do you train on the job this way? How do the off watch people get any proper sleep if they have to get up to help the new guy? Just who is going to break in the only mate or the only engineer? How does anyone get 8 hours of proper continuous sleep on a 6 hour two watch system?

We are already working 14 to 18 hour days in spite of the 12 hour rule. A 5 and 7 hour watch has been suggested as a way of maintaining the two man watch schedule while providing more quality sleep. Changes in meals, lighting and other life style habits have been suggested to further enable two watch system standers to get sufficient sleep with this schedule. There are two problems with this. First, it is generally agreed that humans need 7 to 8 hours of continuous sleep to be truly refreshed. Even with 7 hours off watch you can’t get seven hours of sleep. Meals, hygiene, calls of nature, drills, safety meeting, etc. see to this. Second, the typical work day frequently goes beyond 12 hours anyway.

Why have we been avoiding the obvious safe solution? Four on eight off is a tried and true system. Technicalities of vessel size and load do not change the human bodies’ requirements. They don’t change psychological factors either! If this isn’t important, why has there been so much study over so many years! An even more poignant question is why is it taking so long to make a decision? The 4 on 8 off schedule for 24 hour vessels of ANY description is long overdue.

More people, shorter hours and higher pay doesn’t sound like the recipe for reduced operating costs. But, has anyone stopped to consider the cost of accidents? Are overworked employees trying to think outside the box to save the company money? Tired and overworked employees on the front line of your business are not going to improve efficiency or look for business opportunities for the company. If they were to do this, it would improve the bottom line for management and the employees, but the tired, exhausted and abused don’t see this. They only see the next barge, the next chore, the next meal and most important the next nap which all too often will end far too early.

Let’s look at the whole picture. We need to take a win/win attitude between crews, management and the USCG. If we can meet on common productive ground, everyone will benefit. By all means let’s give Subchapter M a chance. Systematic record keeping and management methods can certainly help improve our industry. Unfortunately, increased paperwork comes with this record keeping. We badly need these records, but we need to ensure that all required paperwork gives a real return of safety and efficiency and we don’t need boat crews that are too exhausted to comply with the management methods of Subchapter M properly.

Let’s ensure that all of this paperwork is necessary and we need the 4 on 8 off watch system yesterday while increasing crew manning to a realistic level.

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About Donald Bates.Brands

Boats, the sea and travel have been my life. I think I was about eight years old when I got my first boat, a dilapidated canoe. A few years later I graduated to a healthier canoe with a lateen sailing rig. This was my first sailboat. I capsized it a lot, but had thoroughly caught the boating bug. I started racing sailboats by the age of 12.

In 1968 I joined the Coast Guard at the age of 17 and was discharged in 1975 with the grade of First Class Quartermaster. My first tour in the Coast Guard was an oceanographic trip to Africa on the CGC Rockaway. It was a three month tour with most of the time at sea, but it was my first adventure out of the country and I loved it. During this tour we put into Liberia, the Ivory Coast and Angola. My second oceanographic tour on this ship took me to the Barbados, Trinidad, the Bahamas, and Puerto Rico. Later in this hitch I was transferred to the CGC Lilac, a triple expansion steam buoy tender, a fugitive from museums built in the early Thirty’s. I believe it is now being refurbished in NY City for display in the near future. I returned to the CGC Rockaway to finish my first hitch and made a Cadet cruise to England.

Discharged from the Coast Guard on Oct 22, 1971, I returned to England for a 3 month tour by bicycle. In January of 1972 I rejoined the CG and reported aboard the buoy tender CGC Firebush at Governors Island NY. In the summer of 1972, I took leave from the CGC Firebush and enjoyed a two week cruise along the south coast of England with a British friend on his 27’ Trident class sloop. This was a bilge keel rig that proved to be fairly important in an area with 30 foot tides. Many times at low tide we were aground, but vertical resting on the two keels.

After returning stateside to the CGC Firebush, the wanderlust hit me again and I requested and received a transfer to the CGC Gallatin which was making a cadet cruise through Europe. On this trip I got to Gibraltar, Portugal, Germany, Denmark and England. In 1974 I bought the Chesapeake Skipjack “Pale Moon” and sailed it from Maryland’s Eastern Shore to NY for Opsail ’76. Throughout this period I was involved in one design racing.

Since my discharge from the Coast Guard in January of 1975, I have been working on large seagoing tugboats and currently hold a 1600 ton Ocean Master’s License as well as Unlimited Third Mate and an Unlimited Radar Observer endorsement. I have written marine safety and cruising destination articles for Offshore Magazine and other publications. On my free time, I enjoy cruising with my wife on our Catalina 22 on Long Island NY’s Great South Bay and other travel adventures.

You can reach me at my email: [email protected]

LIKE me on Facebook at http://www.facebook.com/bates.brands

You can view more information about me on my Shakespir Profile page at: https://www.Shakespir.com/profile/view/dbrands

All questions, comments or suggestions are welcome and appreciated.

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Other Ebooks by Donald Bates-Brands

If you enjoyed this ebook; I would like to suggest that you check out my other ebooks.

Scooters on the Great South Bay 2015. February of 2015 ranked as the third coldest recorded winter in the US. This presented the Great South Bay Scooter sailors of Long Island NY a rare treat. Scooters are antique ice boats that can sail over bad ice relatively easily. Originally a work boat, it has no rudder, steering with the jib. There were 14 Scooters on the ice this weekend. Whole families came down to enjoy the event.

An Old Salt’s Guide to Free Maritime Websites is a list of the various websites that I have found useful to the mariner. Some is real time information, like weather and sea conditions; other sites are for marine charts and publications. All information, electronic charts and electronic publications accessible from these sites are free. All web locations are hyperlinked for easy reference.

An Old Salt’s Practical Guide to Boating is a basic boating guide, told in a salty tale format. Emphasis is on the practical and not on calculations and theory that the average boater doesn’t need. The author has over 40 years of experience on the water as a pleasure boater, Coast Guardsman and commercial tug captain. This is an easy reading and entertaining way to become a proficient boater.

Costa Rica a Land for all Seasons is a detailed description of one couple’s experience with two trips to Costa Rica. One in the dry season and one during the rains. Each trip was different and fascinating in its own way. We found a small country with a lot to say concerning ecology, peace and responsibility for the environment. We thoroughly enjoyed the tropical experience with a friendly and engaging people.

Costa Rica un País Para Todas las Estaciones es una descripción detallada de la experiencia de una pareja con dos viajes a Costa Rica. Uno en la estación seca y otra durante las lluvias. Cada viaje es diferente y fascinante. Encontramos un pequeño país que tiene mucho que decir a la ecología, la paz y la responsabilidad por el medio ambiente. Disfrutamos mucho de la experiencia tropical con una gente amable y agradable.

Life on a Coastal Tug Pleasure boaters will frequently see tugs and ships, but were they anything other than a moving blip on the seascape to the observer? I have worked on coastal tugs for over thirty years and I can tell you that it’s not just a skill and a job, but an entire way of life. This book gives an idea as to what daily life is like on a commercial, sea going tugboat.

An Old Salt’s Guide to Sex after Sixty. Ah, the Golden Years. The kids are out of the house. Time for passion and sex, and then comes a reality check. This book is a humorous, practical, and very enjoyable guide to the sensuous side of life after age sixty. It will show you how to rediscover yourselves. This isn’t magic. It is about learning to talk and play while learning new sensuous and exciting things to do together. Read & enjoy!

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The Arrival of SubChapter M - Reality Check

As of June 20, 2016 Subchapter M is officially here. It is supposed to address many issues in the towing industry and make our profession much safer. Everything has been addressed including fire fighting, supplies, record keeping, drills, surveys, inspections, training, navigation, security, lifesaving, etc. Everything, except for Manning and Work Hours. Everything except for the most important issue in the entire package. We can have the best equipment, with the best shoreside support team, with the best policies, training and guidance, but what does any of that matter if the crew is exhausted? Exhausted crews get injured more often, make bad decisions and fall asleep on watch. Manning is the most important part of Subchapter M

  • Author: Donald Bates-Brands
  • Published: 2017-01-18 22:35:08
  • Words: 3791
The Arrival of SubChapter M - Reality Check The Arrival of SubChapter M - Reality Check