Complying with USCG Regulations

A commercial master of a vessel (in this instance, a USCG certificated small passenger vessel, less than 100 gt), is ultimately responsible for the safety of the passengers, crew and vessel. The USCG views the master as having a key role in being able to break a chain of events, which could lead to a marine casualty. Submitted to the USCG, Long Beach, Calif., this article endeavors to explain, in layman's terms, the steps required to comply with the USCG regulations: While working in the marine industry for the past 40 years, as both a marine safety officer and licensed captain, I feel the need to remind captains of their responsibilities. Occasionally, a captain of a vessel is also the owner; but more often than not, the captain is one of many, employed by a large corporation. Although the corporation does bear the responsibility of following regulations and saftey procedures, the responsibility for the safety and well-being of the passengers is ultimately that of the captain. This is a tradition well-founded in Admiralty Law and statute. Therefore, several guidelines exist to ensure this is accomplished. First, all official USCG memos and updates must be forwarded to the captain, as it is imperative he be current on all rules and regulations. To ensure this, the captain should inquire monthly of his employer concerning any memos that have been received, or, better still, request he be put on the USCG's mailing list. Direct contact between USCG inspectors, captain and crew during annual exams are a valuable source of knowledge concerning the rules and regulations, especially any changes. Second, the captain needs to read and understand the USCG Certificate of Inspection for the vessel, which he is operating. This certificate will inform him where the vessel is permitted to operate, the number of passengers he is allowed to carry, any additional lifejacket requirements and any other requirements the USCG may impose on that particular vessel. For example, USCG regulations state inspected passenger vessels are required to carry approved life preservers suitable for children equal to at least 10 percent of the total number of persons carried, or enough for the number of children actually onboard, whichever is greater. Although, generally, 10 percent of the total lifejackets is adequate, it is up to the captain or crew to do an accurate head count before leaving the dock to ensure every child has a lifejacket and knows where they are located. It is also important to follow the posted stability letter and any draft lines or loading marks the vessel may have. The corporation is required under 46 C.F.R. 185.420 to conduct and keep training logs. It is still the responsibility of the captain to confirm this by reviewing and verifying the training records of each crew member. This assures the captain that 46 C.F.R. 185.420 is followed for abandon ship and manoverboard drills and 46 C.F.R. 185.524 is followed for firefighting drills and training. Official logbooks are required of at least 100 gt or for vessels that go on foreign voyages, as per 46 U.S.C. 11301. Keeping a written logbook is not required, but highly recommended. Voyage plan, passenger count and passenger safety orientations are now required by 46 C.F.R. Part 185, Subpart E. Testing and servicing the EPIRB must be documented and logged under Subpart G 46 C.F.R. Part 185. Review of logbooks prior to getting underway, especially for relief captains, are an excellent way of keeping track of the overall condition of the vessel and crew. The captain needs to be aware of the seaworthy condition of the vessel and the state of the repair and readiness of all lifesaving and firefighting equipment. The captain has a responsibility to inform the owners on conditions of the vessel that would place the vessel beyond the parameters of the Certificate of Inspection or good marine practice. If the captain faces managerial pressure to conduct voyages that would place the vessel passengers, crew and marine environment in jeopardy, the captain needs to speak out and have his concerns put down on record. In extreme cases, the captain should refuse to get underway until conditions are rectified. True, one may lose his job, but will ultimately retain his license as opposed to having it suspended or revoked at an administrative hearing. Taking time to implement each of these procedures will ensure the captain is current and in compliance with all USCG regulations.-Anonymous Master