The Arrival of SubChapter M - Reality Check

       Donald Bates-Brands
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THE ARRIVAL OF SUBCHAPTER M — REALITY CHECK
Published by Donald Bates-Brands at Smashwords
Text Copyright 2017 Donald Bates-Brands
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Table of Contents
The Arrival of SubChapter M – Reality Check
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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.
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(c). 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
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