Since the publication of Subchapter M, many AWO members have expressed concern with the rule’s requirements to carry three day and three night visual distress signals (e.g. flares) aboard towing vessels on Rivers routes, noting that there are other, more effective, means for inland towing vessels to notify nearby vessels of a distress condition.

The Coast Guard has now approved an alternative arrangement proposed by AWO that provides a level of safety equivalent to the carriage of VDS: a distress notification procedure that towing vessels operating exclusively on Rivers routes can incorporate into their Towing Safety Management System.

Under the alternative arrangement proposed by AWO, writes Caitlyn Stewart, AWO’s Senior Director – Regulatory Affairs, the distress notification procedure would include instructions to personnel on board the towing vessel to make a radio call for assistance to vessels in the vicinity and/or to nearby terminals, facilities, barge fleeting areas and Coast Guard stations, and to notify the company’s shore-side personnel via satellite or cellular telephone or connection. In its approval letter, the Coast Guard has indicated that the distress notification procedure must also include the following elements:

  • How the vessel initiates distress notification via VHF radio and cellular/satellite phone to company shore-side personnel;
  • How the vessel alerts passersby to the emergency condition;
  • Critical information to be passed in a distress notification, including vessel location; and
  • Contact information for vessel shore-side personnel, who must be available 24/7 to receive a distress notification.
  • In addition, vessels exercising this option must also have a cellular or satellite telephone located at the operating station with reliable coverage of the vessel’s entire route.

For a vessel to utilize the alternative arrangement, the TPO or OCMI must verify that all the elements of the Coast Guard approval letter have been met, and the alternative arrangement must be documented by the OCMI in the vessel’s COI.

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