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Transport Canada > Marine Safety Home Page > Transport Publications | Marine Safety > The Impact of Regulations on Towing Vessel Safety: A Comparative Evaluation of Canadian and American West Coast Tug and Barge Operations (2004) | TP 14315 | Marine Safety

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10.0  SUGGESTED MODIFICATIONS TO CANADIAN REGULATIONS

10.1 Tug Construction

  • Based upon this study, the regulations covered in Table 10 could be considered as redundant or unnecessary regulations, adversely affecting both the competitiveness and international compatibility of the Canadian Towing industry:

Table 10   Regulations to Consider Eliminating

Regulation Regulation No. Clause Requirement Application Reason to Delete Alternative Approach
Hull
Construction
Regulations		 Part VIII 110 Remote operated WT doors Tugs > 24 m Very expensive Permit use of typical dogged doors
    104 Down-flood any compartment aft of engine room without deck edge submersion Tugs > 5 GRT Illogical, and uniquely Canadian requirement Evaluate practicability of having one-compartment standard of subdivision in all tugs, especially those above 24 m
Towboat Crew
Accommodation
Regulations		     Full range Tugs > 5 GRT, plus other hurdles at 22.9 m loadline Contradicts majority of other standards Harmonize with BCTOA towboat Crew Accommodation Standards, OSHA requirements, and other international IMO standards for crew accommodation
Marine
Machinery
Regulations		 MMR
Sch IV
Pt II		 Section 6-15 Plan approval of internal combustion oil engines Engines > 375 kW Engines are a universal product, approved by Class or similar  
    Section 6 Div I Plan approval of reversing and reduction gearing > 375 kW Gears are a universal product, approved by Class or similar  
    Section 6 Div II Shafting systems for propulsion, electrical generators, and motors > 375 kW These are a universal product, approved by Class or similar  
    Section 6 Div III Propellers > 225 kW These are a universal product, approved by Class or similar  
  MMR
Sch VIII
Pt I		 Section 4 Div I (1) Automation standards Periodically unattended machinery spaces Duplication and overlapping of requirements These requirements are well-defined by IACS member companies, and could be referenced directly

10.2 Tug Inspections

  • There is no evidence that the calendar-based regulatory inspection regime present in Canada results in safer tugs than in the USA, where the vast majority of tugs are not subject to regulatory inspections of any kind. The adoption of a time-based system of vessel self-inspection, rather than a calendar-based system, similar to that developed by the AWO under their Responsible Carrier Program scheme is strongly recommended

for ROBERT ALLAN LTD.

Robert G. Allan signature      

Robert G. Allan, P. Eng.
President

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Last updated: 2006 02 10 Top of Page Important Notices