Monday, September 16, 2013



Editor's Note: 11/9/2015 The NMA closed its doors over a year ago. Its numbered reports will soon be available through the Library of Congress. Most of the issued described in this 2013 post remain unresolved , at least to the satisfaction of America's professional mariners, who now have less voice than ever in matters of marine safety, but always have the final responsibility and liability.

   U.S. Army Corps of Engineers Push Boat                                           
EDITOR'S NOTE: The National Mariner's Association is not a union and does not engage in collective bargaining but does represent the interests of 126,000 working merchant mariners and officers in the domestic trades such as the offshore oil industry support vessel fleet, Inland, Great Lakes and Coastal towing, ferries, and excursion boats in matters of marine safety and Coast Guard administration of the Merchant Marine. The association studies the issues carefully and publishes the association's analysis in a series of numbered bound reports. The Towing Safety Advisory Committee is an official Coast Guard sponsored advisory committee that is supposed to provide the "industry" view to the U.S. Coast Guard on matters of safety regulation. Management members of the industry are generally paid by their companies to attend and corporate "compliance officers" and "safety managers" are paid to stay in constant communication with the Coast Guard to insure that the view of management is heard on all safety matters. That voice has been consistent through the years. If a matter of safety or occupational health will increase operating costs the "industry" is opposed. Of course the voice of the crewmen is never as loud or constant. In the example below the only organization with a real mandate to speak for the labor side of the industry can't afford to go to the meeting. A number of important issues will be decided in this meeting for which the NMA lobbied Congress expensively and fruitlessly last spring and summer. These very real safety needs of the crewmen were documented in the NMA's "Second Request to Congress" and in these pages in our series "BLOOD ON BROWN WATER" which is actually an annotated and illustrated on line version of an NMA numbered report by the same name. If you have not already done so you may read "BLOOD ON BROWN WATER"by clicking here and scrolling down:

 If you don't have time to read it now just remember that it is our "Merchant Marine Interest" pages which are listed in the right hand margin at the Station Identification and Notice Board simply click on "Merchant Marine Interest" and when you enter scroll down until you find the title "BLOOD ON BROWN WATER".  To learn more about the NMA, work boat industry safety issues or to obtain any of their reports click on:

BELOW IS THE ASSOCIATIONS ALERT THAT ANOTHER TSAC MEETING IS SCHEDULED AND A DESCRIPTION OF THE AGENDA ITEMS. In red below various agenda items we have posted the AAIS understanding of what will no doubt be rubber stamped at this meeting . Of course the rubber stamp of TSAC doesn't automatically translate into regulations but it is an important step down that slippery slope.

MEMO TO: National Mariners Association Supporters

FROM: Richard A. Block

Date: August 19, 2013

Subject: Towing Vessel Manning.  (Second Notice)

     The next TSAC meeting will be held in Chicago.  I attach a copy of the Federal Register notice to provide full details.  I would like to know if you plan to attend the meeting and, hopefully, report back on the meeting.  At present, it appears that the lack of funds may prevent us from attending this important three-day meeting and speaking on behalf of the working mariner if and where necessary.  We will submit documents for consideration to the Docket (#USCG-2013-0605 at

   Task 13-02 “Recommendations Regarding the Manning of Inspected Towing Vessels” will be discussed and probably approved.  You have had the opportunity to read this as we e-mailed it to you on August 14th.  What do you think of it.  We want your opinion on towing vessel manning in writing ASAP!!!  Is TSAC going in the right direction?  Is there really an undermanning problem?  If so, did they overlook it?  We will present your opinions it in a revised and updated version of NMA Report #R-276-K.  We want your opinion on Towing Vessel Manning “on the record.”  This may be your last chance to offer an opinion.  We need it ASAP.  I attach a copy of the report for you to consider.  We use our Mariner #s instead of names for your comments. 

AAIS/AAB EDITORIAL NOTE: Carrying too small of a crew to reduce fatigue and handle routine operations is a chronic problem in the offshore service vessel industry and towing industries. None of these vessels carry sufficient crew to possibly perform routine duties like mooring, or "live boating" near an offshore rig when they are manned to the minimum standard stated on their certificates of inspection. It is impossible to run these vessels without violating the minimum rest requirements specified in the International standards. But that is no legal problem for management since based on their lobbying efforts the Coast Guard led delegation to the International Maritime Organization secured an exception for U.S domestic industries assuring that American seamen in the domestic trades between states or from our mainland to off shore areas under U.S. jurisdiction would not have the protection of seamen from nations like Panama, or Liberia. The Congress turned a deaf ear to the NMA last summer when they asked for a law restoring certain additional crewmen positions such as designated cooks and "utility men" to vessels allowed to operate on a two watch system (minimum 12 hour work day). These crew men were once common on these vessel and their jobs were eliminated to improve profits. However that meant that the work of the cook and the "utility man" ( a crewman who turns out as needed with no set watch) had to be absorbed by the remaining crew. So now instead of carrying three deckhands, one of which keep irregular but limited hours just two are carried and the off watch deck hand called out again whenever needed assuring no one gets adequate rest.  Whoever does the cooking has to get that done along with his full load as a deck hand. These are just a few of the examples of "under manning" that is rampant in the industry. The odds are right now that with TSAC's blessing the Coast Guard will put its seal of approval on the status quo. Non Mariner's have a stake in this; fatigued mariners have hit quite a number of bridges in the past causing more than a few deaths among the unsuspecting general public which has no idea of how the Coast Guard superintends the Merchant Marine. Again, to read more about the NMA stand on under manning read BLOOD ON BROWN WATER   or
contact the NMA:

Mariners have other horses in this race.  Here are just a few:

   Task 12-03, “Recommendations for the Enhancement of Towing Vessel Operational Stability.”  This is an important issue that has led to the capsizing and sinking of many towing vessels.  The subject of stability was not covered on many towing vessel officer license exams or in training courses.

AAIS/AAB Editorial Note:Towing vessels do not take on cargo, and the stores, fresh water, and fuel they take on and expend go into tanks and other well planned storage. The basic stability characteristics of tow boats don't change like a cargo vessel's do and that is why the ability to do stability calculations was never on the Towboat officers exams. But there are too many capsizings and sinkings. Why? It will take some research and investigation to find out. Simply applying the type of stability calculations contained in cargo ship officer examinations will not eliminate the problem because it doesn't come from the circumstances that drive the requirement that cargo and tanker officer demonstrate proficiency in calculating stability. One common cause of towboat sinking that we are familiar with is simply inattention to water tight integrity, simply cruising about with water tight doors and hatches open. This is especially dangerous on boats with low free board which is the case with most inland tow boats. Curing that problem would not require testing for the higher math skills involved in stability calculation. Unfortunately management wants neither new professional testing requirements nor a closer look into this problem since that might result ultimately in some design changes of operational practices changes that involve some additional over head. Without a strong labor presence representing the seamen whose lives are at stake, would anyone care to guess what kind of treatment this issue will get at the upcoming TSAC meeting?

 New Tasking “Recommendations for the Improvement of Marine Casualty Reporting.”  This is one of our Association’s major issues.  Hundreds of mariner personal injuries that require “treatment beyond first aid” are never reported to the Coast Guard as required.  Written reports are expected within 5 days.  In addition, Congress expects all injuries or illnesses reported in the vessel’s Official Logbook.  That’s the Master’s responsibility.  There will be a crackdown.  I attach a local Marine Safety Information notice.

AASI/AAB EDITORIAL COMMENT: The under reporting of marine accidents to the Coast Guard has been a known problem for decades. A recent attempt by the DHS Office of Inspector General (audits) failed to get a real handle on the extent of this problem. The NMA has offered strong documentary evidence to both the Coast Guard and the DHS OIG that demonstrates that somewhere between 97% and 80% of "reportable accidents" (as defined in regulation) in any given year go unreported to the Coast Guard. Since the Coast Guard begins with skewed safety statistics you can begin to imagine how funding and planning for marine safety programs are affected.

   New Tasking “Recommendation to Establish Criteria for Identification of Air Draft for Vessels and Towed Vessels.”  This is an issue that our Association petitioned the Coast Guard for rulemaking.  Take this example:  You are asked to tow a barge loaded with equipment that towers above your pilothouse.  Nobody tells you “how high” the load is; but you are ordered to get underway.  You approach a low bridge or power line.  Now what?  NMA Report #R-293-B, Rev. 7.  Will TSAC accept this tasking?

AAIS/AAB EDITOIRIAL COMMENT: Every towboat captain has a right ,duty , and obligation to refuse a dangerous tow. Being expected to tow a tall object under a bridge or power lines without any knowledge of the objects height (the bridge or power line clearance can be found on navigation charts and references) is an unacceptable condition and the tow should be refused. However management and the Coast Guard refuse to back Captains up. Managers fire Captains who refuse dangerous tows and the Coast Guard responds with "that's a labor issue we can't
    get involved". We beg to differ. The Coast Guard examines and licenses merchant marine officers in the interest of public safety, exactly to assure that vessels are competently commanded and that critical navigation decisions are not made by desk bound pencil pushers. Failure to back their licensees when they buck management on safety issue is contra- productive to the purpose of licensing in the first place and looks for all the world like simple cowardice. 

   New Tasking “Recommendations regarding the American Waterways Operators Report on Steel Hull Repair for Towing Vessels.”  We hope that the towing industry has moved beyond its attempt to have the Coast Guard legitimize the use of “doubler plates” in making repairs to towing vessels.

AAIS/AAB EDITORIAL COMMENT: Hope springs eternal, but greed and moral cowardice are constants.


For AAB:
Johnas Prebyster


Richard A. Block
National Mariners Association
B.A., M.S., Ed.
Master #1186377, Issue #9
124 North Van Avenue
Houma, LA 70363-5895
PHONE: (985) 851-2134
FAX: (985) 879-3911

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