How Much Does Your Boat Weigh? GRT vs. GT

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

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!

SUBCHAPTER ‘M’ – OPTIONS – How did we get here and what are my options?

It was a quiet and foggy morning on September 22, 1993 as the Amtrak “​Sunset Limited
​ ” was heading east near Mobile Alabama, towards its ultimate destination of Miami, FL. Unfortunately for the 200 passengers and crew on that train, at approximately 0245, in this same foggy condition up ahead of them, the Captain of the tug MAUVILLA, pushing several barges, was having difficulty determining exactly where he was located and where he could lay up his barges to wait out the fog. Unsure of his position, the barges struck the Amtrak railroad bridge, which crosses Big Bayou Canot, dislodging the tracks from and damaging the bridge.

A mere eight minutes later, while the Captain and crew of the tug were trying to free the barges from the bridge structure, the Sunset Limited, with 3 locomotive units, baggage and dormitory cars, and six passenger cars went off the bridge and into Big Bayou Canot at 72 miles per hour. Fuel tanks on the locomotive cars ruptured and a large fire ensued. So intense that it burned off the fog in the immediate vicinity. Tragically, 42 passengers and 5 Amtrak crew were lost and several more were injured.

It is worth noting that the Captain of the tug saved 17 people from the bayou and I believe, was at a great disadvantage in this situation. He was not provided with the tools needed to safely navigate in reduced (zero) visibility conditions. He was not required to be formally trained in how use the vessel’s RADAR for not only collision avoidance, but navigation as well. And the company didn’t appear have a sound plan on how to deal with these types weather and operating conditions. All of which may have prevented this tragic loss of life.

The NTSB, which investigates all modes of transportation accidents, especially those involving loss of life, made several findings after this tragedy. Some of which have to do with why the Coast Guard promulgated regulations that now require towing vessels to comply with new vessel inspection laws. Also known as ​Subchapter “M”
​ of Title 46 U.S. Code of Federal Regulations. Prior to ​Subchapter M
​ , other regulatory changes were made, such as a new towing vessel licensing and training scheme, training requirements for the use of RADAR, and vessel navigational and safety equipment requirements.
For towing vessel owners and operators trying to sift through ​Subchapter M
​ , it is akin to navigating up a bayou in zero visibility without an operational RADAR or proper charts on board. Considering that the Coast Guard has not been funded to train more marine inspectors, Subchapter M allows companies to use Third Party Organizations (TPOs) to oversee their safety management systems, thus ‘verifying’ compliance on behalf of the U.S. Coast Guard. The Coast Guard will still visit your vessel periodically, issue your initial Certificate of Inspection (COI), and monitor the TPOs and how they, in turn, monitor your operations. Of course this all comes at a cost.

Towing vessel operators are now be required to pay an annual U.S. Coast Guard vessel inspection fee of $1030, ​per vessel​, under the category of ​‘any inspected vessel not listed in this table’
​ (46 CFR 2.10-101). ​And ‘​seagoing towing vessels
​ ’ will be required to pay an annual fee of $2915​. “Seagoing” refers to those operating outside of the Boundary Line. This annual fee is required regardless if you use the TPO option or chose to have the Coast Guard visit your vessel on an annual basis. Third Party Organizations are private entities, which are free to charge fees for conducting vessel internal or ‘external’ vessel audits (more on audits in a later blog!). They are approved by the U.S. Coast Guard and only those organizations can act in this manner.

However, there is another option. Subchapter M allows towing vessel owners and operators to use the “​Coast Guard Option
​ ”. By choosing this option, a Coast Guard marine inspector will visit each vessel annually, ensuring compliance. The COI will be issued during the initial visit and is good for 5-years. Each year after that, they will visit each vessel and conduct an inspection to make sure the vessel remains in compliance. Scheduling of these inspections does require filling out the proper forms and planning ahead as resources are limited in some Coast Guard Sectors. However, each office has personnel that specialize in these regulations, and marine inspectors are trained in dealing with all kinds of inspected vessels, including towing vessels.

In addition to COI inspections, each vessel will be required to be dry docked and inspected while it is out of the water. This will have to be done twice during the 5-year COI period, for those operating in salt water and once during the 5-year COI period for those operating in fresh water for a majority of the time. Those using the TPO option will coordinate with those organizations and will incur the costs of those visits as well. However, with proper planning and scheduling, the Coast Guard will also be able to come and visit the vessel out of the water, and conduct what is known as a “hull inspection”, for those using the Coast Guard option.

The process of obtaining and maintaining a Certificate of Inspection (COI) can be daunting and somewhat confusing under the structure of these new regulations. However, options are available and being apprised of those options can save your company time and resources. Subchapter M is here and it comes with a lot of questions. But we can help you answer ALL of those questions and what is best for you and your operation!

Simulator Training: The Future of Towing Endorsements in the Tugboat Industry

At Maritime TOAR Assessments, we understand how important obtaining a towing endorsement is for Mariners looking to advance into wheelhouse positions. Since 2009, we have assisted Mariners in their completion of USCG Towing Officer Assessment Records (TOAR).

The simulator training facility at Northeast Maritime Institute in Fairhaven, Massachusetts provides training and assessment scenarios to Mariners for Inland, Near Coastal/Ocean and Western Rivers endorsements.

Our simulator, the Class A full bridge tug simulator with 270 degree field of view, uses the most current navigational equipment, providing quality and realistic visualization. It also has multiple configurations for ASD, Western River towboats with flanking rudders, and conventional twin screw tugs with real HW controls. The tug’s towing winch and necessary components are realistically comparable to actual tug operational systems, which enables the mariner to be assessed in all maneuvering tasks including berthing, anchoring, MOB (man overboard) drills, and streaming tow on tugs.

In today’s industry, the benefits of bridge simulators bear a great deal of resemblance to flight simulators when comparing methodologies of assessing and training potential tug boat operators. When real time operations cannot be engaged because it is not assessable, dangerous or unacceptable while the vessel is on charter, the bridge simulator allows the Mariner to be trained and assessed in performing controlled tasks in various environmental conditions, like restricted visibility—all without risking the safety of the crew, public or equipment.

From vessel familiarization, rules of the road, maneuvering, and standard operations, our program offers advantages and opportunities to improve operator performance in realistic conditions that they will encounter in their future tug boat operating career.

Maritime TOAR Assessments program is customized to incorporate all required USCG assessments. Our simulator training is optimized to achieve the best results through our training management system. In one centralized system, it reliably monitors the performance of potential officers of towing endorsements and designated examiners’ data grades to ensure regulatory compliance.

After undergoing the realistic situations within the simulator and being safely trained or assessed on how to approach them by our licensed designated examiners, newly endorsed mariners can feel confident that they’ve been assessed and have received ample training to sufficiently build on their advancement in the towing industry.

If you’re ready to take the next step in your career, obtain your TOAR from Maritime TOAR Assessments.