Month: October 2018

How Much Does Your Boat Weigh? GRT vs. GT

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Many times in my consulting business I need to know what the “Gross Tonnage” of a particular vessel is. This will be the driving force of MANY regulations and how they affect a mariner’s licensing progression as well as the myriad of regulations that may affect the vessel’s operation and regulatory process. Many mariners and vessel operators are still unsure of what “tonnage” is and how it is determined.

Often the answer I receive is “my boat weighs 40,000 lbs”. They may be confusing this with “displacement” which is a measurement of how much water a vessel displaces, based on the volume of water being pushed aside by the submerged portion of the hull. This has absolutely nothing to do with gross tonnage.

There are two measurement systems used to determine a value for gross tonnage of a particular vessel. There is the “Regulatory” tonnage system, which is our U.S. Domestic tonnage measurement system. The initials for this are “GRT”, which is found on a vessel’s certificate of documentation (COD), a certificate of inspection (COI), or in some cases a “tonnage certificate”. Under the Regulatory System there are various formulas that allow spaces to be deducted. GRT is an INTERNAL VOLUME measurement of your vessel based on the dimensions of your vessel, such as Length, Breadth, and “depth” (not draft). The Coast Guard will accept formal admeasurement calculations from classification societies, such as ABS and once it’s officially documented with a GRT, that IS the tonnage that will be used for regulatory purposes.

The second measurement system is called the “Convention” tonnage system. This is based off of the International Convention of Tonnage Measurement of Ships, 1969. Yes, that’s correct, 1969! This system uses the same basic principle of measurement of the internal volume (carrying capacity) of a vessel, but is much less forgiving with respect to “exempted” spaces and formulas that allow this. The initials for this system are “GT” and you may also see this tonnage listed on a vessels COD or COI if it is measured under this system. In some cases a vessel may be measured under BOTH systems. This system is required for vessels built after a certain date and for those that are international trade.

The STCW code uses the Convention tonnage system as it’s basis for the convention’s rules and regulations pertaining to the certification of mariners. Within the code, the United States was able to have the International Maritime Organization (IMO) place “equivalencies” within the scheme for two of our U.S. tonnage endorsements. These are 200 GRT and 1600 GRT. Under this equivalency clause, 200 GRT is equal to 500 GT and 1600 GRT is equal to 3000 GT. This also applies to vessel’s measured under our GRT (Regulatory) system and when STCW applies. For example, a commercial vessel that is over 200 GRT, sailing beyond the Boundary Line (46 CFR Part 7), which is considered “seagoing”, the STCW code applies to that vessel and the mariners employed on board. This is because the vessel falls under the category of vessels of 500 GT or more, under the STCW code.

This can be very confusing on both a licensing and vessel operational scheme. Please contact us today if you have any questions!

TSMS vs. TVR? Confusion Reigns for Many Towing Vessel Owners

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Many small towing vessel operators and owners are still confused by the division of
Subchapter “M” or what I like to refer to the “bipolar” nature of the way these regulations are
being rolled out to the industry. It is very important for all owners to understand the process as
much as what regulatory changes apply to them. Therein lies much of the confusion.

While no one disagrees that all companies should have a “safety management system”
that ensures that operators are clear on their responsibilities, communication processes, and
safe operating procedures, it has come to our attention that some third party organizations and
consulting firms are not making ALL options known to companies and letting them decide on the
best options based on both a financial, cost benefit analysis, as well as a safety risk
management analysis. The first thing that ALL towing vessel owners should know is that there
are two sets of regulations under Subchapter M. These are referred to in layman’s terms as;

1. The Coast Guard Option; OR
2. The Third Party Option.

These two options have very significant and separate processes associated with them.
Under the “Coast Guard” option, owners will be working directly with their local USCG OCMI
(Officer in Charge of Marine Inspection) office. Who will be sending a marine inspector to the
vessel to conduct a COI (Certificate of Inspection) inspection, as well as annual follow-up
(mid-period) inspections. With this option, the Coast Guard will be the the “auditor” who will
verify that the vessel meets ALL safety and operational requirements. They will also verify that
the vessel is properly documenting certain operations in what is known as a Towing Vessel
Record (TVR). A TVR is NOT a towing safety management system. It can be a written OR
electronic record that captures items noted in 46 CFR 140.915.

Under the “Third Party Option”, the Coast Guard will only visit the vessel for the initial
COI inspection and during it’s renewal, five years later. However, before the Coast Guard will
come for its initial inspection, the owner must be operating under the auspices of a Third Party
Organization and a Towing Safety Management System (TSMS) for at least 6-months. Under
that system, the Third Party Organization will be issuing a TSMS “certificate” stating that the
company is in substantial compliance with their safety management system. These audits are
required 2 times during a COI period as well as other internal and external vessel audits (visits)
during the 5-year COI period, to ensure that each vessel is in compliance. It is ONLY under this
option that the owner must have a robust TSMS in place and in operation across the fleet.

For more questions please contact us today!