Ensuring the smooth and effective implementation of new licensing requirements for towing vessel officers will be the most critical USCG-industry challenge as the November 2000 effective date approaches, AWO told the USCG. In its comments, AWO reiterated its support for the new approach to towing vessel officer licensing contained in the agency's November 1999 interim rule.
"We believe the interim rule, with its emphasis on practical demonstration of operational proficiency, will enhance industry safety by ensuring that newly licensed towing vessel operators meet rigorous standards of training and experience," AWO wrote. "We also appreciate the USCG's recognition of the experience and competence of currently licensed towing vessel operators, who will be grandfathered into the new licensing structure consistent with their past experience."
Implementing the new requirements will be a significant challenge, requiring the development of clear, practical, and comprehensive policy guidance and consistent application of that guidance by USCG field units, AWO said. AWO urged the USCG to establish a Towing Safety Advisory Committee
(TSAC) working group to provide guidance on key implementation issues, such as the content and format of the towing officer's assessment record, the guidelines for conducting a demonstration of proficiency, and grandfathering procedures for current licenseholders. AWO recommended the TSAC working group bring together USCG headquarters
, National Maritime Center
, and Regional Examination Center staff in a cooperative effort with towing industry representatives, including licensed mariners.
AWO also suggested several changes and clarifications to the interim rule. Given the limited scope and authority of the Harbor Assist license, AWO recommended reducing the service time required to receive a Master (Harbor Assist) license from 48 to 36 months. AWO also urged the USCG to clarify the documentation requirements for license renewal are not as extensive as the towing officer's assessment record required to obtain an original license, and to permit service time accrued on either an oceans or near-coastal route to be credited interchangeably.