AWO
(continued from page 27)
try licenses without any commen-
surate benefit to the industry or to
safety. In part, through the efforts
of AWO, and the understanding
by the Coast Guard, it is expected
that current towing licenses will
be certified as an equivalent under
the IMO Convention. It is ex-
pected that the Coast Guard will
issue a supplemental notice of pro-
posed rulemaking on licensing in
the next few months.
On another issue, what can be
so simple as drawing a line? The
apparent simplicity soon disap-
pears if a different world of regu-
lations for licenses, crew size, con-
struction and equipment lies
beyond the line. To make matters
more complicated, draw additional
lines for different requirements
and cross the lines here and there.
A recent rulemaking on boundary
lines to implement various stat-
utes was issued by the Coast
Guard, and it presented just such
problems.
AWO developed charts showing
the numerous boundary lines es-
tablished by current law and reg-
ulation. The charts were viewed
by the Coast Guard at a TSAC
meeting and detailed written com-
ments were submitted to express
the confusion which now exists as
a result of the boundary line pro-
posals. This thorough analysis
conducted by AWO will no doubt
assure that clarity will be achieved
in the expected boundary line
rulemaking. A supplementary no-
tice of proposed rulemaking is an-
ticipated in the next few months.
In response to the Coast Guard's
pilotage proposal, AWO conducted
an economic impact survey to de-
termine the cost of employing pi-
lots on seagoing tank barges over
1,000 gross tons. The total bill to
the industry for 1982 would have
exceeded $88 million with no dem-
onstrated increase in safety and,
in fact, the probability of a de-
crease. A final rule is expected
which will permit towing vessel
operators to do their own pilotage.
Pending benzene regulations by
the Occupational Safety and Health
Administration followed by Coast
Guard implementation of those
standards for the marine industry
has great significance not only for
benzene, but for all chemicals car-
ried by tank barge. The standard
for benzene will no doubt serve as
a mode) for the carriage of all
other disease-causing chemicals.
AWO has formed a subcommittee
to anticipate this rulemaking and
they are ready to respond appro-
priately when the time comes. The
subcommittee is currently study-
ing information on marine person-
nel exposures as well as looking at
experiments that member compa-
nies have conducted on equipment.
An opportunity to change the
time intervals for dry docking in-
spected vessels and for tailshaft
examinations has developed be-
cause of an advance notice of pro-
posed rulemaking issued by the
Coast Guard. Through AWO, both
inland and coastal operators are
reviewing their experience with
dry docking. This information will
be tabulated and a recommenda-
tion will be made by AWO at the
next TSAC meeting tentatively
scheduled for October 11, 1984, in
Washington, D.C.
On another front, there are many
federal laws and regulations with
which the industry may or may
not be complying, or which even
the Coast Guard may not be ac-
tively enforcing because the viola-
tion of such regulations and laws
is not causing marine casualties.
However, these laws are still on
the books and when an issue
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